Hernandez v. City of Hanford

In 1989, the City of Hanford (Hanford) (defendant) created a Planned Commercial district (PC district). Furniture stores and the sale of furniture were not included as permitted uses within the PC district, because Hanford did not want the PC district to have a negative effect on Hanford’s downtown commercial district, which had a large number of regionally well-regarded furniture stores. In 2002, Adrian and Tracy Hernandez (plaintiffs) wanted to start a home-furnishing store in the PC district. In February 2003, Hanford issued the Hernandezes a certificate of occupancy, permitting the store to sell home-furnishing accessories but specifically excluding all types of furniture. The Hernandezes then opened their home-furnishings store. Subsequently, the Hernandezes were cited for offering furniture for sale in violation of the zoning ordinances. The Hernandezes sent a letter to the Hanford city council, complaining that the zoning code was being discriminatorily applied, because the PC district included several large department stores that had sold furniture and not been cited. Subsequently, the city council held a study session to consider the issues raised by the Hernandezes’ letter. The study session was attended by the Hernandezes, representatives of the downtown furniture stores, and representatives of the PC district’s furniture stores. Following the study session, the city council decided that it was advisable to amend the 1989 zoning ordinances to create a limited exception, permitting large department stores within the PC district to sell furniture from a single location in the store measuring no more than 2,500 square feet. The Hernandezes sued, arguing that the ordinances banning small stores from selling furniture in the PC district but permitting large department stores to do so were invalid because: (1) the primary purpose of the ordinances was regulating economic competition, and (2) the ordinances violated the Equal Protection Clauses of the federal and state constitutions. The trial court rejected the Hernandezes’ claims, but the court of appeals reversed. Hanford petitioned the Supreme Court of California for review.