Construction Industry Association v. City of Petaluma Case Brief Summary | Law Case Explained

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Construction Industry Association v. City of Petaluma | 522 F.2d 897 (1976)
In Construction Industry Association versus City of Petaluma, we’ll see whether zoning regulations that limit growth in a city are constitutional.
Petaluma, California, is a city about forty miles north of San Francisco. In the 1950s and '60s, Petaluma was a relatively small town that experienced a steady population increase. However, between 1970 and 1972, Petaluma’s population increased by 25%. In 1972, the Petaluma city council adopted several resolutions to limit growth, referred to as the Petaluma Plan. The purpose of the plan was to preserve the city’s small-town character and ensure that development in Petaluma would be reasonable over the next five years. Specific regulations in the plan included limiting housing developments to 500 new dwelling units every year and distributing building permits evenly between single-family homes and apartments. The plan also created a 200-foot-wide greenbelt around Petaluma, which would act as a boundary for urban expansion.
Two landowners and the Construction Industry Association of Sonoma County, collectively referred to as the association, sued the city of Petaluma. Among other issues, the association argued that the plan violated the Fourteenth Amendment of the United States Constitution, including the right to travel. The district court found that the express purpose, as well as the actual effect, of the city’s plan was to exclude a substantial number of people who would’ve otherwise moved into the city. The court held that the plan unconstitutionally denied the right to travel by limiting population growth in Petaluma. The court enjoined the city from implementing the unconstitutional elements of the plan. The city appealed.
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