Southern Burlington County NAACP v. Township of Mount Laurel (Mt. Laurel I)

Case brief summary

Facts

Mount Laurel's zoning mostly allowed only expensive homes or industry, banning apartments, mobile homes, and small affordable houses. Officials admitted this aimed to keep taxes low by discouraging poorer residents and large families.

Procedural history

A trial court struck down the town's zoning law and ordered a housing plan for court approval. The town appealed, and the state supreme court took the case directly, skipping the mid level appeals court.

Issue

Can a growing suburban town use its zoning power to make it practically impossible for low and moderate income families to find housing there, mainly to protect its local tax base?

Holding

No. Growing towns must use zoning to realistically allow various housing types, including affordable housing, covering their fair share of regional needs, unless they show special reasons not to.

Reasoning

Zoning power comes from the state and must be fair, not just protect a town's tax base. Since housing is a basic need, courts must require towns to plan for everyone's housing, not just their finances.

Opinions

Majority (Hall): Towns violate state constitutional fairness guarantees if their zoning blocks low and moderate income housing without a strong justifying reason.

Concurrences (Mountain, Pashman): Mountain would base the ruling on the zoning statute's wording rather than the constitution. Pashman agreed but wanted broader, faster rules applied to all towns statewide.

Dissent: None, all justices joined in the result.