Siena Corporation v. Mayor and City Council of Rockville, Maryland

Courts must not determine a law’s constitutionality based solely on government assurances of good will

Cases > Equality Under the Law > Siena Corporation v. Mayor and City Council of Rockville, Maryland
Loss: The Fourth Circuit Court of Appeals held that a city's interest in zoning and land use policies can justify a complete and targeted ban on construction of self-storage facilities within 250 feet of a public school.
Case Court: Fourth Circuit Court of Appeals

Siena Corporation wanted to build a self-storage facility in Rockville, Maryland, but was thwarted when the city, at the behest of NIMBY neighbors, adopted a last-minute zoning change preventing the project. Siena sued but the district court upheld the zoning change as a “rational” exercise of the city’s police power. Siena appealed, arguing that the Due Process Clause of the Constitution and its right to earn a living were violated and that the court must look beyond the government’s bare assertion that it had a good reason for its actions. PLF filed an amicus brief arguing that constitutional protections mean little if the courts are willing to rubber-stamp government action.

Siena Corporation bought the property at the heart of this lawsuit to open a self-storage facility. The City Council supported Siena’s plans and made various changes to its laws to facilitate the process. Siena obtained site-plan approval based on the Planning Commission’s finding that the project posed no health or safety concerns, and the city manager later wrote that there were no traffic concerns whatsoever. After the purchase, some neighbors complained to the Council that they perceived that the development would impact their property values. Based on these complaints, the Council amended its zoning regulations to prohibit self-storage facilities within 250 feet of a school zone. Siena’s proposed facility was the only one affected by the rule. If Siena can prove that the city acted at the behest of neighbors, rather than to protect public health and safety, the Council’s actions would unconstitutionally violate Siena’s right to earn a living because the zoning amendment would not be rationally related to a legitimate government purpose.

The district court accepted the government’s bare assertion that the law was rational and refused to inquire whether the law actually furthered any valid public health or safety purpose. The court even refused Siena the opportunity to conduct discovery to obtain information essential to proving its claim. Siena appealed and PLF filed an amicus brief supporting the company’s rights. PLF argues that although the “rational basis” test is deferential, courts must not ignore a plaintiff’s evidence that may overcome the presumption of a law’s constitutionality. Instead, courts must give meaning to the right to earn a living by giving teeth to rational basis scrutiny.

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What’s at stake?

  • Under the Constitution, it is the court’s duty to scrutinize laws to determine whether a rational reason truly exists for the government’s restrictions on liberty.
  • When courts use an overly deferential rational basis test, the victims are often minorities and other groups that lack the political power to protect themselves through the legislature.

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