The Ohio House, LLC v. City of Costa Mesa, 135 F.4th 645 (2024)

Citation: The Ohio House, LLC v. City of Costa Mesa, 135 F.4th 645 (2024)
Parent Document: The Ohio House, LLC v. City of Costa Mesa, 135 F.4th 645 (2024)
Jurisdiction: United States (federal)
Effective Date: 2024-12-04
Original Source: https://www.courtlistener.com/opinion/10287865/the-ohio-house-llc-v-city-of-c... ↗

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Turning to Ohio House’s evidence here, it relies on what
it calls “admissions” that “disability was a motivating factor
in the City’s conduct.” These include: (1) the City’s 2015-
2019 reports to the California Department of Housing and
Community Development explaining that its goal in passing
zoning ordinances regulating group housing was to
“[p]rotect existing stabilized residential neighborhoods[] . . .
from the encroachment of incompatible or potentially
disruptive land uses and/or activities” and that it had “taken
. . . action,” including adopting “a Multiple Family Group
Home Ordinance on November 17, 2015 to limit the number
and concentration of group homes and sober living facilities
in the Multiple Family Residential zones”; and
(2) statements made by the City Director of Economic and
Development Services that “the City had ‘a proliferation of
group homes and sober living homes’ and that it had adopted
the group home ordinances ‘as a way to address the
complaints’ received from City residents” and that the City
chose to “‘spread out the group homes in the city’ as an
alternative to ‘citing them all and shutting them down.’”
    Although this evidence taken in isolation might suggest
discriminatory animus, there is countervailing evidence that
the City was motivated by legitimate, non-discriminatory
goals. 13 In passing regulations governing group homes and

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