City of Edmonds v. Oxford House, Inc.

The Fair Housing Act (FHA) prohibits housing discrimination against handicapped people. Section 3607(b)(1), an exemption written into this act, permits any reasonable statute or ordinance that sets the maximum number of occupants a dwelling may contain. The City of Edmonds (Edmonds) (defendant) enacted an ordinance that defined who may occupy a single-family home. It stated that anyone who is related by blood, marriage, or adoption may live together, or if unrelated, five or fewer persons. In 1990, Oxford House, Inc. (plaintiff) opened a group home in a single-family home in Edmonds. Both parties agreed that the residents of the home, recovering drug addicts and alcoholics, were considered handicapped under the FHA. Shortly after opening the group home, Oxford received citations from Edmonds, charging Oxford with violations of the city’s zoning ordinance regarding single-family homes. Oxford House brought an action to challenge the citations. The district court ruled that the restrictions on who was to be considered a family in the Edmonds ordinance was a lawful exemption because it limited the number of occupants residing in a single-family home. Oxford House appealed to the United States Court of Appeals for the Ninth Circuit, which ruled that the exemption in the FHA did not apply to the ordinance in question. Edmonds petitioned for certiorari to the United States Supreme Court.