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Chong Yim v. City of Seattle

Citation: Not availableDocket: 96817-9

Court: Washington Supreme Court; November 13, 2019; Washington; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, plaintiffs, including individual landlords and the Rental Housing Association of Washington, challenge the constitutionality of Seattle's Fair Chance Housing Ordinance under both state and federal substantive due process clauses. The ordinance restricts landlords from considering an applicant's criminal history in rental decisions. The plaintiffs argue this violates their substantive due process rights by infringing on fundamental property interests, warranting heightened scrutiny. The Washington Supreme Court examines whether state substantive due process claims should follow federal standards, ultimately applying rational basis review to the ordinance. The court concludes that property regulation challenges under the Washington Constitution will adhere to federal standards unless a heightened standard is adopted. The court also addresses the applicability of various tests, such as the 'unduly oppressive' and 'substantial relation' tests, in evaluating substantive due process claims. Justice Stephens concurs with the majority on state law issues but dissents regarding a certified question on federal law, asserting it falls outside the court's jurisdiction. The court's decision affirms the ordinance's validity under rational basis review, aligning state and federal substantive due process standards in property regulation contexts.

Legal Issues Addressed

Facial Constitutionality of Housing Ordinance

Application: The case evaluates the constitutionality of Seattle's Fair Chance Housing Ordinance under both state and federal constitutions, focusing on substantive due process claims.

Reasoning: The legal opinion addresses the facial constitutionality of Seattle's Fair Chance Housing Ordinance, which prohibits landlords and tenant screening services from requiring disclosure or taking adverse actions against individuals based on their criminal history.

Judicial Approach to Certified Questions

Application: Justice Stephens concurs with the majority on substantive due process under state law but dissents regarding the court's jurisdiction over a certified question pertaining to federal law.

Reasoning: Justice Stephens concurs in part and dissents in part regarding the certified questions presented by the district court.

Rational Basis Review in Property Regulation

Application: The court applies rational basis review to evaluate the Fair Chance Housing Ordinance, determining it serves a legitimate public purpose without requiring heightened scrutiny.

Reasoning: Ultimately, the court concludes that rational basis review applies and clarified that the plaintiffs' cited cases no longer support heightened scrutiny due to their diminished legal foundations.

Standard of Review for Land Use Regulations

Application: The court establishes that substantive due process claims concerning land use regulations under the Washington Constitution will adhere to the same standards as federal claims.

Reasoning: In the absence of a Gunwall analysis or a principled reason to diverge from federal law, the court maintains that substantive due process claims under the Washington Constitution will adhere to the same standards as federal claims unless a heightened standard is formally adopted.

Substantive Due Process under Washington State Constitution

Application: The court clarifies that state substantive due process claims will follow the same standards as federal claims, applying rational basis review unless a heightened standard is adopted.

Reasoning: The court concludes that unless a heightened standard is adopted, state substantive due process claims will follow the same standards as federal claims, specifically applying rational basis review to the plaintiffs' challenge.