Martin v. Constance

A group of developmentally disabled adults (collectively, Martin) (plaintiffs) lived in a group home owned and operated by the State of Missouri. The home was in Compton Heights, a residential and historic neighborhood subject to restrictive covenants. Martin sued property owners and the Compton Heights Neighborhood Association (the association) (defendants) to enjoin them from enforcing a restrictive covenant that would prohibit the group home’s continuing operation. The suit alleged violations of the federal Fair Housing Act (FHA) and 28 U.S.C. § 1983, which prohibited actors from depriving individuals of their federally protected rights under color of state law. The covenants prohibited any nonprivate residential use of any neighborhood building. During a hearing and bench trial, Martin presented evidence that the group home essentially operated as a functional family, its residents were screened for suitability for community living, and there was minimal turnover in the group’s members. Martin’s expert testified that property values were not adversely affected if a group home with residents like Martin was integrated into a residential neighborhood. The association presented evidence that the restrictive covenant had been enforced against several businesses on previous occasions and argued that it did not specifically target handicapped persons and because there were other such homes in the state, there would be no discriminatory impact on Martin or others like Martin. Neighborhood residents testified who opposed having the group home in their neighborhood because it was a rooming house or business and they feared the state, despite its reassurances, might not maintain the property, which would not be subject to the same restrictions that applied to private owners. The court granted Martin a preliminary injunction.