Smith & Lee Associates v. City of Taylor

Smith & Lee Associates, Inc. (S&L) (plaintiff) was a for-profit corporation that operated Adult Foster Care (AFC) homes throughout Michigan. AFC homes provided 24-hour supervision to adults who need constant supervision but not continuous nursing care. S&L purchased a home, Mortenview Manor, located in a residential neighborhood in the City of Taylor (the city) (defendant). Mortenview housed six elderly disabled residents who suffered from various forms of dementia. Although some AFC homes received government subsidies, Mortenview did not and relied exclusively on payments from residents to operate. Mortenview was located in a residential neighborhood zoned for single-family use. Michigan law allowed AFC homes to house up to six disabled adults in any residential zone. S&L, however, wanted to house 12 residents at Mortenview. S&L petitioned the city to rezone Mortenview from a single-family use classification to a multiple-family use classification. The city considered S&L’s petition in a public hearing and denied the petition because it opposed spot zoning and because rezoning Mortenview would be inconsistent with the city’s master land-use plan. S&L filed a lawsuit against the city, alleging that the city had violated the Fair Housing Amendments Act of 1988 by intentionally discriminating against and failing to make reasonable accommodations for disabled residents. The trial court ruled in favor of S&L, finding both that the city had intentionally discriminated against disabled residents and had failed to make reasonable accommodations for disabled residents. The trial court ordered the city to allow S&L to house 12 residents at Mortenview. The city appealed.