Trailer Industry officially splits
Marlette Homes
Pennsylvania
It is unconstitutional for a township's zoning ordinance to classify mobile homes in residential districts as distinct from conventionally built homes. Courts may inquire as to whether particular zoning classification bears substantial relationship to public health, safety, morals, or general welfare.
Justice Cohen, dissenting in Anstine expressed fear that the holding would be construed to mean that a community could not, under any circumstances, regulate the placement and existence of mobile homes.
Anstine reflects the development of the mobile home industry as well as a very specific understanding of the immediate legal precedent. Anstine, did not challenge the reading of mobile homes as "dwellings" which is largely consistent in the casework. Instead, it focused on the what control local zoning codes could exert. Contrary to both Manchester -v Phillips and Napierkowski -v. Gloucester , Anstine concludes that physical health is the basis for local oversight, not aesthetic or fiscal concerns.
This reading puts Anstine in line with Euclid -v. Zoning by refocusing on health as the primary social welfare.