Hernandez v. City of Hanford
Supreme Court of California
159 P.3d 33 (2007)
The City of Hanford (Hanford) (defendant) created a Planned Commercial (PC) district in 1989 that excluded furniture sales, aiming to protect its downtown commercial district's well-regarded furniture stores from competition. The Hernandezes (plaintiffs) got a certificate of occupancy in the PC district for a home-furnishings store that specifically excluded furniture, then were cited for selling furniture anyway; they complained to the city council that large department stores in the PC district sold furniture without being cited. After a study session with input from both downtown and PC-district merchants, the council amended the ordinance to let large department stores sell limited furniture from a small in-store section, while still barring small stores like the Hernandezes' from selling furniture at all. The Hernandezes sued, arguing the ordinance improperly regulated economic competition and violated equal protection; the trial court rejected the claims, and the court of appeals reversed.
Whether a zoning ordinance that directly and intentionally regulates economic competition, favoring large department stores over small retailers in the sale of furniture, is valid so long as it serves a legitimate public purpose and does not violate equal protection.