Lindquist v. City of Pasadena

Full Case Name
James and Sandra LINDQUIST, Plaintiffs, v. The CITY OF PASADENA, TEXAS, Defendant
Description

The City's Motor Vehicle Dealers Ordinance set boundaries about how close used-car dealerships can be to residential areas in order to curb any detrimental effects on the surrounding residential communities, including nighttime glare and light pollution. The plaintiffs, owners of a used-car dealership, sued the City for denying their dealership's license, alleging an equal protection claim against the City for treating their dealership differently than others. The Court found there was not sufficient evidence for an equal protection claim and dismissed the case.

Date
09-10-2009
Court
United States District Court for the Southern District of Texas
Jurisdiction
United States
Plaintiffs
Defendants
Incident Location
Pasadena, TX
Disputed Act

The City amended its Motor Vehicle Dealers Ordinance, which required used-car dealers to obtain a license for each location at which they sell cars and set boundaries about how close used-car dealerships can be to residential areas. The Ordinance stated in its preamble that its purpose was to curb any detrimental effects on the surrounding residential communities, including nighttime glare and light pollution. The City denied the plaintiffs a license under the amended Ordinance, the plaintiffs appealed, and the City denied that appeal. The plaintiffs sued the City, alleging that the denial of their license-application appeal violated the Due Process and Equal Protection Clauses of the United States and Texas Constitutions.

Holding
The Court found that the plaintiffs "failed to show that the City exercised unbridled discretion in refusing their appeal" while granting others' appeals and that they "failed to raise a genuine fact issue material to determining whether the City intentionally treated them differently from other similarly situated persons without a rational basis." The Court found that even if the City did not follow all the Ordinance requirements, it followed the purpose of the Ordinance. The Court dismissed the case.
Disposition