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Coler v. Cleburne was a United States Supreme Court case that addressed the issue of zoning laws and the Equal Protection Clause of the Fourteenth Amendment. The case involved a zoning ordinance in Cleburne, Texas that prohibited the construction of a home for mentally disabled individuals. The plaintiffs, a group of citizens who wanted to construct the home, argued that the ordinance violated the Equal Protection Clause of the Fourteenth Amendment. The Supreme Court held that the ordinance did violate the Equal Protection Clause. The Court reasoned that the ordinance was based on a classification of mentally disabled individuals, and that the classification was not based on any rational basis. The Court noted that the ordinance was not related to any legitimate governmental purpose, and that it was based on prejudice and fear. The Court's decision in Coler v. Cleburne was significant because it established that zoning laws must be based on rational bases, and that they cannot be based on prejudice or fear. The decision also established that the Equal Protection Clause of the Fourteenth Amendment applies to zoning laws, and that such laws must be based on legitimate governmental purposes.
Justice Field delivered the dissenting opinion in Coler v. Cleburne, arguing that the majority's decision was contrary to both precedent and reason. He argued that a state has broad authority to regulate its internal affairs, including matters of public health and safety, which includes determining who may reside within its borders. The Court had previously held in Yick Wo v. Hopkins (1886) that states could not discriminate against certain classes of people without due process of law; however, Justice Field believed this case was different because it involved an act by a municipality rather than a state legislature or executive branch action. Furthermore, he argued that there were no constitutional provisions prohibiting municipalities from making such regulations as long as they did not conflict with any federal laws or treaties. Finally, he noted that while some might find the ordinance objectionable on moral grounds, it did not violate any fundamental rights protected by either the Fourteenth Amendment or other parts of the Constitution and should be allowed to stand under principles of local self-government established by prior cases like Hunter v Davis (1890).