Show me the contract.
In effect, postwar single-family zoning represented an agreement under which homebuyers accepted restrictions on other types of uses in their neighborhood in order to be protected from negative externalities that neighbors might create, without the protection of the covenant provided by single-family zoning.
To abolish single-family zoning is a violation of the contract between a municipality and its single-family homeowners. They selected the neighborhood and the house based on the protections offered by prevailing zoning.
This is from Robert Poole, “A Brief History of Zoning,” Reason, June 10, 2023.
I’ve been reading Bob Poole’s articles since age 18 and have always learned from them. This is the first time I can think of when I strongly disagreed with something he’s written.
Bob makes a point that some commenters have made when I’ve argued against zoning: namely that people who bought houses under the zoning rules are being betrayed by the elimination of those rules. Bob even goes so far as to say that the local government had a contract with the homeowners.
Here’s the problem. There’s no contract. Instead, the government made a regulation, people bought assets with the idea that those regulations would be enforced, and there’s some chance that if the regulations are relaxed or eliminated, people who own those assets will suffer a capital loss.
But libertarians aren’t typically in the business of saying that on that basis those regulations should be kept. People who bought medallions giving them the legal power to operate a cab in New York suffered a loss when Uber and Lyft were allowed to operate. Should Uber and Lyft be regulated out of existence?
My wife and I own a house in an area that’s zoned R-1. We bought it in 1986 because we liked the house and by using all the cash we had and borrowing and getting gifts from parents, we could barely afford a 10% down payment. But we recognized that the zoning was a government regulation, not a contract. If I could have bought a house in an area that also allowed apartment blocks, and if the presence of those apartment blocks had made our house cheaper, I might have bought such a house. But we didn’t have that option.
Whenever government gets rid of restrictive regulations, people who gained from those regulations will lose. But that doesn’t mean that the government violated a contract.
Later in his article, Bob points out that state governments often put whole areas off limits for development and implicitly suggests that those limits be relaxed or abolished. I agree.
He seems to think that it’s an either/or. Either we abolish zoning or we abolish growth limits. I say that we should embrace the power of “and” and do both.
For more on what I’ve written on zoning, see this and this and this.
READER COMMENTS
MarkW
Jun 11 2023 at 8:56am
I agree it was no more than an implied contract. People thought of buying a house in a single-family zoned neighborhood as sort of like buying a house in a neighborhood with an HOA, where the municipality acted in the role of the HOA board. Or at least some people did. Others, like David and his wife, might have been just as happy to buy a house next to an apartment block, but due to the prevalence of zoning, none such were available.
For us, we live in Ann Arbor fairly close to the university. Here, for a time, developers were able to buy single homes or a couple adjoining houses and build ‘cheap and cheerful’ apartment blocks. This was well before our time here, but apparently at the time they were referred derisively as ‘cash box’ apartments (because they were inevitably little modernist boxes and were apparently very profitable to build). And then the city banned them at some point in the 60s or 70s. But they’re still around as are the fraternity houses, so living next to an apartment building or Greek house is an option. But it’s not what we chose, and we’d have had to have saved a significant amount of money to consider it — apart from the noise, disorder, trash (especially after frequent parties), and general indifference to landscaping , there is the transience and age differences. 18-22 year old students aren’t interested in our lives nor we in theirs really. Living in a quiet neighborhood amongst people know (some of whom we have known for a long time and whose kids grew up with ours), is preferable, for us, to living amongst apartment dwellers. That doesn’t mean I support single-family zoning, but I don’t pretend not to understand the appeal.
The city is actually poised to get rid of single-family zoning, but we’re not worried. Our own little neighborhood is effectively ‘zoned’ for single-family based on economics — the high cost of homes here (for the Midwest anyway) along with the absence of vacant land and its being just a little to far from campus make it an unlikely target for developers, even if they were allowed to start building ‘cash boxes’ again.
A long time ago I had a discussion of HOAs with an acquaintance. I told him that I didn’t think I couldn’t stand living in a place ruled by a bunch of busybodies whereas he thought HOAs were sometimes a necessary evil. He said, “In your (expensive) neighborhood, you don’t need an HOA, but where I live, we do.” And, of course, it’s not hard to see his point — HOAs (and zoning) are a way for people of more modest means to live where ‘genteel’ standards can be collectively enforced — which would otherwise be unobtainable for them (‘lace curtain’ Irish and all that). I do feel a little uneasy about bashing single-family zoning with the knowledge that we, ourselves, are unlikely to be personally affected by the changes and really don’t have any skin in the game.
Jon Murphy
Jun 11 2023 at 9:55am
Poole is making (or reporting on homeowners making) a transitional gains trap argument. There is a perception of a contract (implicit or explicit), removal of a regulation violates that contract, and consequently represents a violation of property rights or a government takings. But there is no takings; no contract was violated. One is not entitled to a certain level of value of their property.
I have seen more and more liberterians making a transitional gains trap argument in everything from trade, to immigration, to zoning.
Of course, as Tullock points out in his article that I linked to, the price of the asset in question (in his case, taxi medallions. In this case, house prices) take into account the monopoly rents, so the newcomers to the market stand to lose real welfare. In turn, this creates a special interest group to challenge the proposal.
MarkW
Jun 11 2023 at 11:00am
But in this case, it’s not clear whether or not removing zoning would raise or lower home prices — it seems less an argument about a financial taking as opposed to changes to non-pecuniary features of neighborhoods. And as I read the article, Poole is not arguing for preserving single-family zoning so much as replacing it with Houston-style neighborhood land-use agreements:
Single-family neighborhoods in Houston are able to form land use agreements that define what homeowners can and cannot do with their property. They are typically of 30 years’ duration, at which time they can be extended, modified, or abolished via a supermajority vote. The Houston city government enforces these neighborhood agreements.
These seem to be somewhere between zoning and HOAs . How should a libertarian feel about zoning vs land-use agreements vs HOAs? Should existing single-family zoned neighborhoods be able to create land-use agreements? Should they be able to create new HOAs?
Jon Murphy
Jun 11 2023 at 4:34pm
You’re right. I should have said “value” rather than price.
Jon Murphy
Jun 11 2023 at 9:36pm
My two cents: oppose zoning, be agnostic between land-use and HOAs.
robc
Jun 12 2023 at 10:08am
Same as Jon, with one caveat:
They are typically of 30 years’ duration, at which time they can be extended, modified, or abolished via a supermajority vote.
I am not sure what the last part applies to? Abolish should happen by default, I am okay with it if the “supermajority vote” only applies to extend or modify. And would prefer “supermajority” to be “unanimous”. Anyone who wants out should be out on expiration.
I would prefer 25 years (or 19, as Thomas Jefferson preferred), but that is being nit-picky. 30 is final.
All “deed restrictions” should expire.
john hare
Jun 11 2023 at 11:07am
This may not be the right place to post this. If unacceptable, I won’t be offended if deleted.
There are many ways to restrict ability to build what’s wanted or needed. In central Florida, building is booming, though recent immigration action seems to be tapping the brakes. My wife and I paid cash and closed on a small lot (quarter acre) in July 2021. I immediately started the process of going for a building permit even though we didn’t have the cash at the time. Trying to build a 1/1 of 620 square feet for as close to cash as possible.
I designed it as a tornado resistant structure of reinforced concrete walls and roof poured on site. (I’m in the concrete business and have done the technical end before on industrial work). F5 tornado max is 319 mile an hour wind with the highest recorded in the US at 304. My concept is that being in the concrete business, we could build our house as a place to live as well as a demonstrator for people that might want an addition that would be a storm shelter as well. We are putting a 6/12 pitch on the roof which gives high cathedral ceilings in the process. We could go into a subdivision and mimic the architecture so the neighbors don’t get upset. That’s the why.
I started looking for a licensed engineer to get some blueprints we could submit for permit. My engineering background is decades old and I never had a degree or license. Several “engineers” wanted nothing to do with it as they were making good money cranking out standard prints that simply met code, or engineering prices for a draftsman’s work. Finally got my partners draftsman to get on it and he would get an engineer to stamp it. That was September through December 2021.
By December, the draftsman had not started yet and I had found an engineer starting his own company and needing the business. Switched engineers and it was still May 2022 by the time I got prints. Gave them to my partner the contractor and told him we were ready for permit. It is required to get a septic tank permit first, and there was already a septic tank and drain field on the property that had been tested. Not good enough, have to get a permit that there is an existing. The septic tank company wouldn’t touch it Because the survey on the county website disagreed with where the property lines were and whether the tank was on our property.
I had located the property pins before we closed on the property, but we had to hire a surveyor to verify. $850.00 later the property moved 18 feet and the septic and drain field were on the neighbors property. Had to apply for a new septic tank permit. Got that late in 2022 and went for a building permit. The serial hold ups in that so far are they want truss engineered drawings, but there are no trusses. We needed 5 acres to build but the lot was platted before the rules were changed. They had to have a duplicate plot plan saying they couldn’t read the original. The engineers electronic signature on the blueprints expired while all this was going on and we had to get that renewed. There’s more, but the bright side is that if we ever get a permit we have most of the cash we need to build and will likely be able to earn enough to get in with no payment.
The point of all this is that if you have permanent staff to address all these issues, you can apply for hundreds of permits at a time and get them in a somewhat timely manner. If you are an individual unfamiliar with the current process, you may have trouble getting through the maze. Housing scarce and unaffordable is not such a mystery with the barriers to entry.
David S
Jun 12 2023 at 4:09pm
Compared to other states, Florida is relatively easy to build in—provided that you don’t do anything unconventional!
The 5 acre lot size requirement is pretty severe.
Michael F. Cannon
Jun 11 2023 at 11:50am
The best analogy here is that of a dude who formed a contract with the mafia to coerce third parties, then the mafia realized it was wrong and stopped, but the dude demands the government not let the mafia breach because sanctity of contracts.
steve
Jun 11 2023 at 4:15pm
Agree there is no contract, its actually hard to think of instances where a contract will exist between govt and an individual taxpayer, but there is also no law or contract that prohibits passing laws/regulations that set limits on what can be built.
Steve
Richard Fulmer
Jun 11 2023 at 11:18pm
There is the (too often ignored) takings clause in the Constitution. Set enough limits on what can be built and the value of a piece of property could fall to zero or even less than zero. If I can’t legally do anything with my property, then all I can do is pay taxes on it.
Jon Murphy
Jun 12 2023 at 7:51am
To Richard Fulmer’s point above, there is a law (or contract): The Constitution of the United States; the Supreme Law of the Land. There are all sorts of disputes over how much authority federal and state/local governments have in controlling one’s property. One such decision was reached just a few weeks ago in Sackett v EPA where a unanimous Supreme Court ruled the federal government does not have the authority to prevent the building of a home near most kinds of water. The federal authority is limited to navigable waters.
Not to mention that many states, following the infamous Kelo v. City of New London decision in 2005 greatly restricted (either through new legislation or constitutional changes) the ability of state and local officials to use eminent domain to compel sale or changes to property.
Courts spend a lot of time sorting out property disputes. There are limitations.
steve
Jun 12 2023 at 12:59pm
So it’s legal to set limits but we are debating the extent of those limits. In the case of zoning, if you already own property in a zone and wanted to build eg an apartment building and were prohibited you wouldn’t lose any value on what you already own so you wouldn’t merit compensation. If you were looking to buy property and then build you wouldn’t lose any money or need compensation since you would never build. Asa practical matter not seeing how it would apply but IANAL and we know people like to stretch the meanings of laws.
““Nor shall private property be taken for public use, without just compensation.” ”
Steve
Scott Sumner
Jun 11 2023 at 5:19pm
Very good observations. I was disappointed when I saw the Poole article, as Reason magazine has generally been very good on housing rights.
MarkW
Jun 12 2023 at 7:41am
FWIW, Reason has also just published (on the Volokh Conspiracy) another criticism of Poole’s argument by Ilya Somin.
I’m still not seeing, though, the libertarian bright line between a municipality blanketed by single-family zoned neighborhoods vs one blanketed with neighborhoods restricted by deed covenants, HOAs, or by Houston-style land-use agreements (enforced by the local government).
Elsewhere, Somin argues that the critical distinction is this:
As a result of these carefully-crafted contractual conditions, 100% of the members of the HOA—past, present, and future—consent to belong.
In stark contrast, local governments essentially never start with unanimous consent. Usually you’re lucky if they even start with majority support….
Yes, that’s true, but doesn’t that distinction cut both ways? HOAs and deed covenants created at the time of development are effectively eternal whereas zoning can be changed by the local democratic process. Zoning, therefore, for all its ills, seems more flexible than private approaches that produce similarly restrictive results.
Jon Murphy
Jun 12 2023 at 7:44am
Consent.
MarkW
Jun 12 2023 at 8:57am
Yes, but at this point there are few or no living property owners who actually experienced zoning being involuntarily imposed upon them. For the vast, vast majority of current owners, a decision to buy in a single-family zoned neighborhood was made with the same level of consent as a decision to buy within an HOA.
The consent argument works well against imposing of new zoning restrictions and even in the case when those coerced and injured by the imposition of zoning are still around, but it seems work less well as an argument that historical, long-standing restrictions should now be removed. The arguments for that involve freeing up opportunities for new residents, not for rectifying historical coercion from the early-mid 20th century. And the modern arguments about opening up opportunities for new residents seem to apply in equal force against zoning, HOAs and other forms of land use restrictions.
Jon Murphy
Jun 12 2023 at 9:45am
Imposition isn’t the problem. It’s exit.
When your only option is to buy in a single-family zone, I don’t think one can call it consent. Same reason why I reject social contract theory.
MarkW
Jun 12 2023 at 10:09am
I guess areas of the country vary widely, but where do you find single-family zoned neighborhoods to be the only option? Around here it’s possible to buy a home in an older single-family zoned neighborhood or in a new HOA controlled development or even out in a nearby rural area on an unzoned multi-acre plot (though some of the townships have unfortunate minimum lot-size rules).
TMC
Jun 12 2023 at 10:12am
“When your only option…..”
How is this your only option? Do you feel the right to force others to change their rules to suit you? You have no right to buy any specific property. Buy in an area that have the zoning you prefer.
As for consent, you do have the option of getting zoning changes on a ballot. All you need is 50% of the renters and homeowners to go along with you.
robc
Jun 12 2023 at 10:11am
As I said upthread, there should be a reasonable time limit on any deed restriction, land use agreement, HOA, etc.
One generation is enough. I favor 25 years, 30 years is fine. Something in that ballpark.
Mark Brady
Jun 11 2023 at 7:20pm
What if the government creates, abolishes, or changes the scope and term (duration) of intellectual property, e.g., copyright?
David S
Jun 12 2023 at 4:15pm
Thank you for this post. I hope I get a chance to use the phrase: “Regulations are not contracts” or something to that effect.
I’m curious when we’ll see our next big court case about zoning. I don’t think the Supreme Court will ever completely overturn Euclid vs. Ambler, but I think they’ll allow lots of state level pushback against obstinate local ordinances. Broad use of private property has a much longer legal history than exclusionary zoning. Most private property owners aren’t even aware of how much freedom they’ve relinquished over the decades.
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