This paper investigates the impact of inexpensive housing obligations in New Jersey on value of dwelling, value of housing, and precise housing manufacturing. New Jersey’s Mount Laurel court docket circumstances established a doctrine whereby municipalities should allow their “justifiable share” of affordably priced housing. At numerous factors since then, the legislature has interpreted this doctrine with particular, quantitative targets for municipalities to succeed in, or it has declined to take action, leaving enforcement as much as the courts, which in flip backed away for a number of years from implementing inexpensive housing targets. These coverage modifications present a possibility to analyze whether or not inexpensive housing targets are having their supposed impact. Primarily based on artificial management evaluation, the outcomes present no impact of inexpensive housing mandates on housing manufacturing and minimal to no impact of inexpensive housing mandates on housing prices.
1. Introduction
The Mount Laurel court docket circumstances in New Jersey established that “a creating municipality could not, by a system of land use regulation, make it bodily and economically unattainable to offer low and reasonable revenue housing.”[1]
Whereas the preliminary ruling merely held that municipal land-use rules couldn’t exclude all the things apart from large-lot single-family homes, the legislature has interpreted the Mount Laurel doctrine to say that municipalities have an affirmative obligation to assemble deed-restricted inexpensive housing. Till 1985, the legislature didn’t act. Municipalities had broadly flouted or challenged the 1975 New Jersey Supreme Court docket resolution, resulting in a “mass of protracted litigation.”[2] In 1983, the Mount Laurel II resolution affirmed a “builder’s treatment” in opposition to municipalities that failed to fulfill judicially decided inexpensive housing targets, thereby incentivizing the legislature lastly to behave.[3]
The outcome was the Truthful Housing Act of 1985, which established an impartial physique tasked with calculating every municipality’s “justifiable share” allotment of latest inexpensive housing items, which might afford them secure harbor from builder’s treatment lawsuits. That physique, the Council on Reasonably priced Housing (COAH), issued its first spherical of justifiable share calculations in 1987, they usually remained in pressure till 1993. Spherical II of COAH’s fair-share obligations have been in pressure from 1993 to 1999, and after 1999 COAH went successfully defunct after its Spherical III calculations have been invalidated by the courts. It was lastly abolished in 2024 in favor of a brand new technique of calculating fair-share obligations. Since 2007, then, when COAH’s Spherical III guidelines have been invalidated, New Jersey municipalities have needed to revert to the previous technique of judicial certification of compliance with the Mount Laurel doctrine.
How have the Mount Laurel doctrine and its assorted interpretations by the legislature affected housing manufacturing and prices in New Jersey? To reply this query, we first want to grasp the political financial system of affordable-housing targets and inclusionary zoning applications.
2. The Results of Reasonably priced-Housing Mandates
So as to adjust to COAH guidelines, New Jersey municipalities adopted inclusionary zoning. Inclusionary zoning is available in two types: necessary and voluntary. Necessary inclusionary zoning requires that any new growth of a specified dimension or sort put aside a proportion of items that should be rented or bought at an inexpensive worth to low- or moderate-income customers. Deed restrictions and revenue verification implement the affordability requirement. Voluntary inclusionary zoning gives a developer a regulatory profit, corresponding to a rise in allowed density, supplied a sure proportion of items are rented or bought at below-market charges in the identical method.
The Truthful Housing Act of New Jersey requires municipalities to develop at minimal a voluntary inclusionary zoning program, however necessary applications are ubiquitous all through the state, in line with a database maintained at inclusionaryhousing.org.
Inclusionary zoning solely features if the market-rate items in an inclusionary growth are costly. The developer has to make a big revenue on these items to offset the losses on the items which might be required to be bought or rented at below-market charges. If housing usually turns into inexpensive, then, inclusionary zoning doesn’t work.
Inclusionary zoning has different curious results. As a type of worth management, it creates shortages and rationing. Extra individuals need the below-market items than can be found, in order that they should be allotted by lottery. Furthermore, inclusionary zoning, at the very least within the necessary kind, reduces the provision of housing, as a result of builders know they may make much less revenue from constructing than they might if there have been no inclusionary necessities.
Empirical analysis largely confirms these theoretical expectations. Analysis within the Baltimore-Washington space finds that necessary inclusionary zoning will increase the price of market-rate housing, although it won’t have an effect on new housing provide (Hamilton, 2021). An earlier research of California discovered that inclusionary zoning insurance policies decreased the dimensions and elevated the worth of single-family homes (Bento, et al., 2009). A research of San Francisco and Boston discovered that necessary inclusionary zoning elevated costs and decreased manufacturing in Boston whereas rising costs during times of rising costs and decreasing costs during times of falling costs in San Francisco, and never affecting manufacturing there (Schuetz, et al., 2011). Yet one more research of California discovered robust adversarial results on manufacturing and costs (Means & Stringham, 2012). There’s just one contrarian research on the difficulty, discovering that discount in inclusionary zoning necessities in components of California didn’t have an effect on home costs (Hollingshead, 2015). It might be that these applications create hysteresis in housing markets as soon as they’re applied.
Whereas these research deal with necessary inclusionary zoning, there are causes to suppose that even voluntary inclusionary zoning, which is rather more widespread, might have adversarial penalties for housing manufacturing, significantly in a state like New Jersey or Massachusetts with a “builder’s treatment” out there when municipalities fail to fulfill inexpensive housing targets.
Suppose that municipal management usually opposes new multifamily growth. If a developer proposes a brand new market-rate multifamily growth, it usually doesn’t instantly assist the municipality meet its inexpensive housing goal, as a result of the items are often not priced affordably sufficient. Furthermore, since housing markets are supra-municipal, corresponding largely to commuting areas, municipal leaders could effectively understand that constructing market-rate housing has solely weak results on the general affordability of housing inside municipal boundaries, contributing slightly to the affordability of housing all through the native labor market. Realizing that they have to meet their inexpensive housing targets, however disfavoring multifamily growth usually, municipal management may have a transparent incentive to disclaim planning permission for market-rate multifamily developments.
Anecdotally, the market-rate nature of a growth (i.e., the shortage of deed-restricted inexpensive items) ceaselessly comes up as a justification for planning denials. State legislation doesn’t expressly defend municipal choices to disclaim planning approval to market-rate multifamily initiatives, however municipalities usually take pleasure in broad discretion to disclaim approval for bigger multifamily initiatives, by means of both website plan assessment, variance, or conditional use allow processes. When a scarcity of deed-restricted inexpensive items is mixed with different options that will justify a denial, corresponding to visitors impacts, a municipal land-use board could really feel themselves on firmer floor to challenge a denial than in any other case.
Anecdotally, the market-rate nature of a growth (i.e., the shortage of deed-restricted inexpensive items) ceaselessly comes up as a justification for planning denials. State legislation doesn’t expressly defend municipal choices to disclaim planning approval to market-rate multifamily initiatives, however municipalities usually take pleasure in broad discretion to disclaim approval for bigger multifamily initiatives, by means of both website plan assessment, variance, or conditional use allow processes. When a scarcity of deed-restricted inexpensive items is mixed with different options that will justify a denial, corresponding to visitors impacts, a municipal land-use board could really feel themselves on firmer floor to challenge a denial than in any other case.
On this manner, a state-level requirement that municipalities meet affordable-housing manufacturing targets will have a tendency to cut back general housing manufacturing and thereby enhance general housing prices.
Have affordable-housing manufacturing targets and inclusionary zoning had these results in New Jersey? We want a reputable empirical check evaluating New Jersey to comparable states.
3. Empirical Evaluation
The empirical technique right here is to check the rounds of binding affordable-housing obligations in New Jersey to the identical intervals in different states and to intervals in New Jersey when there weren’t binding affordable-housing obligations. Of specific curiosity are two outcomes: constructing permits per capita (one of the best measure of housing manufacturing) and two measures of value of dwelling usually and price of for-sale homes specifically. There is just one annual measure of state-level value of dwelling that goes again earlier than 2008 (Berry, et al., 2000). We would not have annual information on rental prices, however the FHA produces an all-transactions home worth index based mostly on resales and value determinations. Their quarterly information are averaged by 12 months to create an annual index.
The end result variables are as follows: 1) complete housing items permitted per capita, from the U.S. Census Bureau, 2) housing items in five-or-more-unit buildings per capita (these housing items are more than likely to be affordably priced), 3) annual change in state value of dwelling, and 4) annual change within the state’s all-transactions home worth index. The annual state-level constructing permits information return to 1980 and as much as 2023. The price of dwelling information return to 1960 and as much as 2007. Home worth information go from 1975 to 2024.
Determine 1 reveals how complete constructing permits per capita have advanced in New Jersey and two neighboring states since 1980. The vertical strains set off the interval of 1985 to 1999, when Mount Laurel obligations have been most critically enforced, and the interval 1999 to 2007, when Mount Laurel obligations have been barely enforced in any respect, as a result of the courts have been ready on a legislative resolution that by no means got here.
Determine 1: Whole Constructing Permits per Capita in New Jersey and Neighboring States
We see right here that earlier than 1985, New Jersey was allowing much more items per capita than Pennsylvania and New York have been. Shortly thereafter, nevertheless, New Jersey allowing plunged, and it remained roughly at Pennsylvania’s degree till about 2012, when the state regained a small however regular benefit over its neighbors. These modifications in allowing don’t line up effectively with the enforcement of inexpensive housing obligations.
Determine 2 reveals how constructing permits for items in buildings with 5 or extra items advanced over time in the identical group of three states.
Determine 2: 5-Plus Constructing Permits per Capita in New Jersey and Neighboring States
The outcomes listed below are much like these in Determine 1, besides that Pennsylvania and New York swap locations. Pennsylvania produces extra housing than New York, however New York produces extra multifamily housing than Pennsylvania, which isn’t stunning since New York is extra urbanized. After 1990, New Jersey’s allowing of bigger multifamily buildings carefully tracks New York’s, however New Jersey did have a barely larger fee between 2016 and 2022.
To date, the uncooked information don’t present a powerful impact of inexpensive housing obligations on housing manufacturing in New Jersey. New Jersey is probably the most densely populated state within the nation, so it is smart that New Jersey would produce a bigger share of multifamily housing than a state like Pennsylvania. However solely in the previous few years has New Jersey produced extra general housing than Pennsylvania. There isn’t a proof that the 1985 to 1999 interval particularly was extra productive of housing in New Jersey than different intervals, or that the 2000 to 2007 interval was significantly unproductive, besides maybe relative to the post-2012 interval.
After all, constructing permits are a measure of amount provided, however economics teaches us that each provide and demand collectively decide an equilibrium. We can not motive from amount modifications alone that New Jersey’s inexpensive housing obligations didn’t work, as a result of maybe New Jersey had abnormally low housing demand, which induced builders to wish to construct much less no matter rules. If inexpensive housing obligations corresponded to intervals of sluggish progress in the price of dwelling in New Jersey, we might infer that these obligations boosted housing provide in spite of everything.
Determine 3 reveals the evolution of state value of dwelling from 1960 to 2007 for New Jersey and its bigger neighbors.
Determine 3: Value of Residing in New Jersey and Neighboring States
This chart suggests as effectively that inexpensive housing obligations didn’t work. Value of dwelling in New Jersey grew extra quickly than in neighboring states between 1980 and 1990 and since then has remained persistently larger. This proof means that demand for housing in New Jersey was rising quickly within the Eighties, and extra housing items would have been provided to fulfill market situations even within the absence of inexpensive housing obligations. It’s even doable that inexpensive housing obligations suppressed provide by means of the regulatory incentives established by inclusionary zoning.
Lastly, Determine 4 plots the annual change in the home worth index for all three states. It is very important be aware right here that the home worth index is particular to every state, so ranges usually are not comparable throughout states, solely modifications are. Each state’s home worth index is ready to 100 within the first quarter of 1980.
Determine 4: Modifications in Home Costs in New Jersey and Neighboring States
New Jersey home costs largely change in lockstep with New York’s. However between 2015 and 2020 there’s a temporary interval when New Jersey’s home costs rose much less quickly than New York’s. We most likely shouldn’t overinterpret six years of information on this time sequence, however in live performance with the proof from Determine 2 it would counsel that the interval of court docket supervision of Mount Laurel obligations was extra productive for housing than both the interval of legislative supervision or the interval when these obligations have been largely not enforced.
Nonetheless, these charts usually are not conclusive. We are able to examine the results of New Jersey’s inexpensive housing obligations utilizing artificial management evaluation (Abadie, et al., 2015). Artificial management creates a weighted common of comparable items to the handled unit, then compares the precise leads to the handled unit to the counterfactual outcomes represented by the weighted common of comparable items. The remedy impact of the intervention equals precise New Jersey’s worth minus artificial New Jersey’s worth on an consequence.
I used the quick lag of the dependent variable, inhabitants, private revenue, land space, and variety of native governments per sq. mile from Ruger and Sorens (2023) to create a “artificial” New Jersey from different states. Within the change in value of dwelling and alter in home costs analyses, I additionally used the one-year lag of the extent of every index to seize any scale results occurring in very long time sequence of worth indices. This artificial New Jersey is as comparable as doable to the true New Jersey, permitting us to analyze the counterfactual constructing permits, value of dwelling, and housing prices that will have occurred in New Jersey within the absence of the Mount Laurel inexpensive housing obligations.
I take a look at two remedy intervals, the primary when the legislature made Mount Laurel obligations efficient from 1985 to 1999, and the second when neither the legislature nor the courts have been implementing Mount Laurel obligations (2000 to 2007). Separate artificial management analyses are run for every interval.
| Final result: | Whole items | Whole items | 5-Unit permits | 5-Unit permits | Δ Value of dwelling | Δ Value of dwelling | Δ Home worth index | Δ Home worth index |
| Remedy interval: | 1985-1999 | 2000-2007 | 1985-1999 | 2000-2007 | 1985-1999 | 2000-2007 | 1985-1999 | 2000-2007 |
| Massachusetts | 0.66 | 0.58 | 0.82 | 0.22 | 0.6 | 0.29 | 0.44 | 0.2 |
| Pennsylvania | 0.24 | 0.17 | 0.17 | 0.22 | 0.52 | |||
| Connecticut | 0.13 | 0.46 | 0.14 | 0.38 | ||||
| New York | 0.02 | 0.23 | 0.17 | 0.28 | 0.09 | 0.16 | 0.01 | |
| Florida | 0.09 | 0.27 | ||||||
| Nevada | 0.07 | 0.04 | ||||||
| Arizona | 0.02 | |||||||
| Hawaii | 0.25 | |||||||
| California | 0.1 |
Desk 1: Development of Artificial New Jersey in Every Evaluation
As a result of I’m working eight completely different artificial management analyses (two remedy intervals mixed with 4 outcomes), the exact content material of artificial New Jersey varies from evaluation to evaluation. Desk 1 reveals how artificial New Jersey is constructed in every evaluation; the numbers signify the weights on every state.
Unsurprisingly, neighboring states New York and Pennsylvania contribute loads to many of those analyses. Massachusetts is the one state that contributes to artificial New Jersey in each evaluation. The largest shock is to see Hawaii enter as a big contributor to artificial New Jersey within the 1985–1999 home worth index evaluation. In any other case, uncommon states make up solely a really small proportion of artificial New Jersey in every occasion.
Predictor steadiness was largely good, with handled and artificial New Jersey matching carefully on inhabitants, private revenue, and efficient competing jurisdictions per sq. mile. Nonetheless, handled New Jersey land space was usually a couple of half to 1 / 4 of artificial New Jersey’s. New Jersey is abnormally small for its inhabitants and private revenue (it’s the most densely populated state), and it’s arduous for the algorithm to copy that sample with different states.
Determine 5 reveals the outcomes of the artificial management analyses of complete constructing permits per capita for the 2 remedy intervals.
Determine 5: Artificial Management Evaluation of New Jersey Whole Constructing Permits
The artificial management algorithm finally ends up replicating New Jersey’s pre-treatment allowing extraordinarily carefully within the precedent days and solely reasonably carefully within the later interval. New Jersey’s precise allowing fell under its counterfactual allowing over many of the earlier remedy interval, akin to the primary legislatively enforced Mount Laurel regime. However the variations are tiny in an absolute sense, and once we bear in mind regular variation in different states, they don’t seem to be statistically vital in any 12 months. The identical is true of the remedy results within the later interval, akin to no enforcement of Mount Laurel obligations, besides in 2000, the place the outcome goes within the “flawed” route (New Jersey constructed greater than anticipated). In different phrases, neither legislative enforcement of Mount Laurel nor a suspension of Mount Laurel made any distinction to New Jersey residential constructing permits.
Determine 6 presents equal outcomes for five-unit manufacturing.
Determine 6: Artificial Management Evaluation of New Jersey 5-Unit Constructing Permits
The outcomes are principally the identical. The one statistically vital outcomes based mostly on standardized p-values are in 1986 and 2000, however they go within the “flawed” route, suggesting that New Jersey had abnormally few five-unit permits in 1986 and abnormally many five-unit permits in 2000.
Determine 7 strikes on to basic inflation. Right here, we might anticipate legislative enforcement of Mount Laurel to cut back state inflation charges and no enforcement of Mount Laurel to extend them, if the system really promoted housing provide.
Determine 7: Artificial Management Evaluation of New Jersey Inflation
Right here, we’re capable of mannequin New Jersey’s pretreatment inflation extraordinarily carefully and precisely. As soon as once more, we discover basically no impact of the Mount Laurel regime. Not one of the remedy results are near statistical significance, besides in 2002, the place the outcome means that the shortage of Mount Laurel enforcement could have added a tenth of a proportion level to the state’s inflation fee. However for many years, the information counsel that Mount Laurel has made no distinction to basic inflation in New Jersey.
Subsequent, Determine 8 seems to be on the outcomes for change within the all-transactions home worth index.
Determine 8: Artificial Management Evaluation of Change in New Jersey Home Costs
The outcomes listed below are all around the map, suggesting that Mount Laurel enforcement raised home costs in 1986 and 1987 and minimize them in 1989, 1990, and 1991. The common remedy impact over the primary interval is -1.2, akin to a couple of 0.5 % change in home costs over the entire 1985–1999 period. After enforcement was eliminated, home costs rose, however solely in two years was that enhance statistically vital: 2002 and 2006. The common remedy impact over this era is 11.7, akin to a couple of 2.7 % change in home costs throughout that period. There’s inconsistent proof that Mount Laurel enforcement stored home costs down barely.
Once we put all this proof collectively, it means that Mount Laurel enforcement didn’t enhance housing provide. It could have minimize housing costs barely with out rising allowing, suggesting a discount in demand for housing, however these modifications have been too slight to make any influence on broader state-level inflation.
4. Dialogue
The outcomes from the foregoing analyses counsel that the Mount Laurel doctrine and a number of rounds of inexpensive housing obligations relationship again at the very least 39 years have achieved nothing, or subsequent to nothing, to make housing extra considerable or inexpensive in New Jersey. It is a disappointing outcome, maybe, nevertheless it’s arduous to see it as a stunning one, since New Jersey stays a expensive state for housing and comparatively slow-growing in comparison with Sunbelt states that make it simple to construct.
A few of the proof means that New Jersey constructed plenty of housing throughout 2015 to 2020, and that this era additionally corresponded to a moderation in home worth will increase. This was a interval of judicial enforcement of Mount Laurel obligations with none legislative framework. Not less than, the outcomes nonetheless assist pessimism concerning the legislature’s potential to give you standards for Mount Laurel compliance that foster progress in housing provide.
These outcomes additionally shouldn’t be stunning because the bulk of the scholarship on the query finds that inclusionary zoning insurance policies are inclined to make housing much less inexpensive, much less considerable, or each. The Truthful Housing Act’s mandating of voluntary inclusionary zoning and encouragement of necessary inclusionary zoning has, at minimal, counteracted the intent of the legislation to make housing extra out there to households of modest revenue.
New Jersey is at present present process a fourth spherical of inexpensive housing obligations, and the method has generated a lot controversy. The legislation, Act 2 of 2024, requires the Division of Group Affairs to develop municipality-specific inexpensive housing obligations underneath an in depth, exact method. These obligations go into pressure this 12 months.
Elements of the legislation’s method are value questioning. To begin with, “Certified City Support” municipalities are exempted solely from the legislation. This would possibly make sense if all of those municipalities already provided considerable inexpensive housing, however that’s not essentially the case. Municipalities can qualify for this record if they’ve a excessive proportion of substandard and poor housing or just a excessive inhabitants density.
Second, Potential Want – the brand new inexpensive housing obligation – is calculated on the belief that 40% of the housing demand in each area and in each municipality will come from low and reasonable revenue (LMI) households. This ignores the chance that LMI households desire to stay in some locations slightly than others (as an example, locations with entry to public transit or walkable to employment).
Communities find yourself with a better quota if they’ve had extra speedy industrial valuation progress over the earlier decade. This provision encourages communities to squelch industrial growth. Furthermore, industrial valuation progress doesn’t essentially suggest employment progress. Good-growth ideas counsel utilizing employment progress as a substitute to find out housing want.
The method additionally consists of an revenue capability issue, which punishes communities not only for being rich, but additionally for having a small inhabitants, as a result of it averages a purely income-based measure with a household-weighted income-based measure. To keep away from penalizing communities for having a small variety of households, the measure ought to merely be the household-weighted measure.
The legislation does bear in mind land capability of the municipality, which is meant to cut back new housing obligation for already built-out municipalities. Nonetheless, the calculation relies upon partially on Geographic Info Programs (GIS) land-cover and tax map information which might be typically not sufficiently granular, correct, and up-to-date for the aim.
Lastly, the “allocation elements” are merely averaged to supply the justifiable share calculation, with no justification. For instance, the small neighborhood of Monmouth Seaside has complained about its optimistic Potential Want quantity, on condition that it has zero developable land.
Given these issues, it’s no marvel that the renewed inexpensive housing obligations are going through robust resistance across the state. Typically state governments do have to put guardrails on the municipal zoning energy, however usually, mandates on the variety of items to supply don’t work effectively, as a result of they encourage wasteful litigation, and municipalities are sometimes capable of keep away from them by means of sub rosa strategies like delaying permits, requiring further research, and zoning land for growth that’s not really developable.
5. Conclusion and Suggestions
Is the Mount Laurel doctrine working for New Jersey? Not in its legislative interpretations to this point. The legislative framework based mostly in 1985’s Truthful Housing Act has demonstrably failed to unravel the inexpensive housing drawback in New Jersey. In actual fact, there’s no proof it has elevated allowing in any respect, and treasured little that it has introduced down the price of housing within the state.
Three suggestions for reform observe.
- As talked about, Act 2 exempts city municipalities from inexpensive housing mandates. This exemption makes little sense if one’s aim is to offer extra inexpensive housing the place there’s demand for it. Act 2 might due to this fact be amended to use to all municipalities within the state, and the quantitative housing mandates recalculated. Some lawmakers could query this strategy on the grounds that larger inexpensive housing mandates for suburban and rural municipalities shall be extra prone to cut back residential segregation. However it’s a usually legitimate maxim that when one goals at two targets directly, one dangers hitting neither. A greater option to cope with segregation could be to handle its adverse penalties instantly.
- A modest reform would shift inexpensive housing targets from municipal to regional our bodies, both the present county planning boards or new regional authorities created by laws. These our bodies might assessment growth functions particularly for inexpensive housing developments, in session with the municipalities concerned. A regional goal system could be extra versatile than the present municipal goal system, and will permit market demand to have a larger say in the place these initiatives happen.
- New Jersey lawmakers ought to contemplate repealing Act 2 solely and talk about methods to leverage non-public property rights and the free market to develop housing provide, corresponding to by conferring particular growth rights for sure sorts of initiatives based mostly on website and infrastructure situations.
- The state can even velocity up allowing with shot-clocks, third-party allowing, and broadened exemptions from particular allow necessities. The Mercatus Heart publishes an annual report on the state legislative “toolbox” for housing, a helpful supply of concepts on this entrance (Furth, et al., 2024).
As a substitute of detailed inexpensive housing mandates which have spawned a whole litigation trade, the state ought to transfer towards regulatory reforms aimed toward basic housing abundance. The state might nonetheless financially reward cities that really allow plenty of new constructing, however these rewards ought to come after the permits have been issued, not after mere rezonings. This strategy would construct a extra collaborative relationship between the state and municipalities and likewise make it simpler for builders to know what they’ll construct and the place, with out having to undergo years of authorized rigmarole. These reforms would make housing extra considerable the place it’s wanted, bringing down the price and doubling down on New Jersey’s current financial strengths, like a talented, urbanized workforce and powerful industrial and port infrastructure.
Acknowledgments
The creator thanks Audrey Lane for editorial assist and steerage and nameless referees for useful suggestions. All remaining errors are the creator’s accountability.
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Finish Notes
[1] Southern Burlington County N.A.A.C.P. v. Township of Mount Laurel, 67 N.J. 151 (1975).
[2] Monaghan, Justin M., and William Penkethman Jr. “The Truthful Housing Act: Assembly the Mount Laurel Obligation with a Statewide Plan.” Seton Corridor Legis. J. 9 (1985): 585–619, 587.
[3] Southern Burlington County NAACP v. Mount Laurel Township, 92 N.J.
158, 456 A.2nd 390 (1983).