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Shaler Township v. Zoning Hearing Board of Shaler Township — A Landmark Zoning Ruling

Jan 23

Shaler Township v. Zoning Hearing Board of Shaler Township — A Landmark Zoning Ruling

Shaler Township, a residential community in Allegheny County, Pennsylvania, recently found itself at the center of a significant land-use dispute. The controversy culminated in a Pennsylvania Commonwealth Court decision issued on December 23, 2025 in Shaler Township v. Zoning Hearing Board of Shaler Township (No. 1704 C.D. 2024), which affirmed a lower court ruling that struck down a township zoning ordinance amendment as unlawful spot zoning.

The Background: Who and What

At the heart of the dispute was a Township zoning ordinance — specifically Ordinance 1974 — that amended the definition of “family” in the Township’s zoning code (Section 225-218). The amendment was intended to allow up to six unrelated disabled persons to live together in a residential home as a protected class under the Federal Fair Housing Amendments Act (FHAA), something previously limited to a household of three unrelated people.

The change was prompted by a long-running conflict involving a property on McElheny Road that a developer and rehabilitation provider hoped to use as a group home for disabled adults. After litigation and a settlement agreement in federal court, the Township amended its zoning code to specify this “six disabled persons” language, aiming to ensure compliance with federal fair-housing requirements.

Neighbors — Patrick and Allison Murray and Robert Neely — challenged this ordinance, arguing it was substantively invalid because it amounted to unlawful spot zoning: a rezoning that benefits a specific property without proper planning or justification and that is arbitrary or capricious.

What the Courts Held

Zoning Hearing Board & Trial Court

The Shaler Township Zoning Hearing Board agreed with the neighbors, concluding that the amendment effectively singled out the neighboring property and thus constituted spot zoning. The Allegheny County Common Pleas Court affirmed that decision, allowing the challenge to stand.

Commonwealth Court Review

Shaler Township appealed the trial court’s ruling to the Pennsylvania Commonwealth Court. The Township raised several arguments, including:

  • that the neighbors lacked standing to bring the challenge;
  • that changed circumstances had mooted the issue; and
  • that a text amendment of this kind shouldn’t be treated as spot zoning because it applied Township-wide.

But in the December 23, 2025 decision, the Commonwealth Court affirmed the trial court’s ruling. The Court held that:

1. The neighbors had standing to challenge the ordinance.
2. The issue was not moot, even with subsequent agreements affecting the property’s use.
3. The ordinance amendment amounted to unlawful spot zoning, because — in practical effect — it conferred a special benefit on the property at issue without reasonable justification tied to the zoning plan.

As the court explained, “Spot zoning is the unreasonable or arbitrary classification of a small parcel of land…with no reasonable basis for the differential zoning.”

Why This Matters

This case is more than a local land-use squabble. It highlights the delicate balance between:

  • Fair housing obligations (like those imposed by the FHAA),
  • Local zoning authority and legislative power, and
  • Protecting neighborhoods from regulatory changes seen as targeting specific properties.

By finding the ordinance invalid as spot zoning, the courts reinforced the doctrine that even well-intended amendments must be rooted in a legitimate planning purpose and applied in a way that doesn’t single out particular parcels without justification.

Takeaways

  • Municipalities must carefully craft zoning amendments with sound planning rationale.
  • Broader legal obligations (like fair housing) don’t automatically validate zoning amendments if they function as special privileges to individual properties.
  • Neighbors affected by zoning changes have recourse to challenge amendments they view as arbitrary under spot-zoning principles.

If you’re a homeowner, planner, attorney, or local official, this case is a useful reminder: zoning changes are powerful tools — but they must be wielded with respect for both fair process and sound planning law.