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1 Potomac L. Rev. 207 (1978)
Arlington County Board v. Richards: Equal Protection and the Means-Focused Analysis in Social and Economic Regulations

handle is hein.journals/potolor1 and id is 213 raw text is: RECENT DEVELOPMENTS
ARLINGTON COUNTY BOARD v. RICHARDS:' EQUAL
PROTECTION AND THE MEANS-FOCUSED ANALYSIS
IN SOCIAL AND ECONOMIC REGULATIONS
The United States Supreme Court, holding a community's enact-
ment of parking restrictions valid, utilized a means-focused test in
assessing challenges to economic and social regulatory legislation
when such legislation was alleged to violate the fourteenth amend-
ment's equal protection clause.
Facts
On May 18, 1974, the County Board of Arlington amended section
29 D of its zoning ordinance, empowering the city manager to au-
thorize permit parking on streets in districts zoned residential., The
preamble of the ordinance states the purpose to be:
to reduce hazardous traffic conditions resulting from the use of
streets within areas zoned for residential use for the parking of
vehicles by persons using districts zoned for commercial or in-
dustrial uses. . .; to protect those districts from polluted air,
excessive noise, and trash and refuse caused by the entry of such
vehicles; to protect the residents of those districts from unreason-
able burdens of gaining access to their residences; to preserve the
character of those districts as residential districts; to promote
efficiency in maintenance of those streets in a clean and safe
condition; to preserve the value of property in those districts; and
to preserve the safety of children and the pedestrians and traffic
safety. . . .3
The constitutional validity of the ordinance was challenged by
appellee who was an employee in Crystal City, a commercial high
rise development in which 20,000 people were employed. Due to
1. Arlington County Board v. Richards, 413 U.S. 24 (1977).
2. Whenever the county manager determines on streets of a residential district that 25%
of the number of parking spaces are being occupied by vehicles whose destination is a district
where industrial or commercial uses are permitted, and the total number of spaces actually
being occupied by any vehicle exceeds 75%, he shall restrict parking to those residents issued
permits, their visitors, persons doing business with residents of that district and service or
delivery vehicles providing services to those dwellings. Arlington County, Virginia, Zoning
Ordinance, § 33 D(1) (1961).
3. Arlington County, Virginia, Zoning Ordinance, 0 29 D Preamble (1961).

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