Robinson Township v. Knoll – Case Brief Summary
Summary of Robinson Township v. Knoll, 410 Mich. 293, 302 N.W.2d 146 (Mich. 1981).
The Knoll family (Ds) placed a mobile home on their property after the effective date of a zoning ordinance amendment that provided that mobile homes were permitted only in mobile home parks. Knoll had not obtained a building permit, but he had dug a well, obtained a septic permit, and made a number of other improvements with county approval in preparation for setting up the home.
Robinson Township sued to compel the Knolls to remove the home from their property. Knoll claimed in that the ordinance was unconstitutional. The court of appeals held for Knoll and the plaintiff appealed.
- May a city zone property to exclude mobile homes from certain residential areas?
Holding and Rule (Levin)
- No. A city may not zone property to exclude mobile homes from certain residential areas under the Due Process clause of the Fourteenth Amendment.
The court held that the per se exclusion of mobile homes from all areas not designated as mobile home parks has no reasonable basis under the police power and is therefore unconstitutional as a violation of substantive due process. The court was unable to identify any inherent characteristics of mobile homes that justified a per se prohibition against them. Concerns based on aesthetics, health and safety are illusory. Hence the ordinance is unconstitutional.
The defendants have the burden of showing that no governmental interest is being advanced by the present classification. They have not sustained that burden. The ordinance does not restrict mobile home parks to any particular zone but merely requires approval. The police power extends to imposing reasonable regulations to safeguard residents against the fact that mobile homes are more susceptible to windstorm and fire damage which increases the probability of injury to persons and property in the surrounding area. Classifications may also take into account property values. This zoning classification is reasonable and Knoll has failed in his burden of proof.
See Adarand Constructors, Inc. v. Peña for a constitutional law case brief holding that statutory racial classifications must be analyzed under a strict scrutiny standard, and are constitutional only if they are narrowly tailored and advance a compelling governmental interest.