Caspersen v. Town of Lyme
New Hampshire Supreme Court
661 A.2d 759 (1995)
The Caspersens (plaintiffs) owned 800 acres in a forestry-designated district under a town ordinance requiring 50-acre minimum lots, and challenged the ordinance as exclusionary and unconstitutional even though they had no actual intention of building low-income housing on their land; the town's stated goals for the district were preserving large land tracts and encouraging forestry, and evidence showed 50 acres was the minimum size at which forestry became profitable. The trial court upheld the ordinance, and the Caspersens appealed on multiple grounds including substantive due process.
Whether a zoning ordinance's minimum lot-size restriction violates substantive due process when the restriction is rationally related to the town's legitimate, conceded zoning goals.