Village of Arlington Heights v. Metropolitan Housing Developement Corp., No. 75-616 Suprme Court of The Unite States 429 U.S. 252; 97 S. Ct. 555; 1977 U.S. LEXIS 28; 50 L. Ed. 2d 450
January 11, 1977
CORE TERMS: village, rezoning, discriminatory, racially, housing, zoning, Fourteenth Amendment, single-family, motivation, integrated, motivating, classification, disproportionate, rezone, site, tenant, build, multiple-family, injunctive, nonprofit, Fair Housing Act, zoned, moderate, securing, buffer, contingent, departure, invidious, moderate-income, acre
Interested in building a racially integrated, low and moderate income housing project of 20 buildings and 190 units on a 15-acre parcel of land within a village, a nonprofit development corporation entered into an immediate lease of the land and also into a sale agreement for the land contingent upon the corporation's obtaining zoning clearances from the village and housing assistance from the federal government. The development corporation applied for rezoning of the land from single-family to multiple-family classification, but the village denied rezoning, thus preventing construction of the project. The development corporation and three Negroes then brought an action for declaratory and injunctive relief in the United States District Court for the Northern District of Illinois, alleging that the rezoning denial was racially discriminatory and violated, among other things, the Fourteenth Amendment and the Fair Housing Act (42 USCS 3601 et seq.). Ruling in favor of the defendant village, the District Court held that when rezoning was denied the motivation had not been racial discrimination or intent to discriminate against low income groups, but a desire to protect property values and the integrity of the village's zoning plan, and, moreover, concluded that the denial of rezoning would not have a racially discriminatory effect (373 F Supp 208). On appeal, the United States Court of Appeals for the Seventh Circuit reversed, finding that the rezoning denial violated the equal protection clause of the Fourteenth Amendment, since, although it agreed with the District Court that rezoning had been denied without a racially discriminatory motive, the Court of Appeals found that the racially discriminatory effects of the rezoning denial, which had a disproportionate impact on blacks, did not serve compelling interests (517 F2d 409).
THE COURT HELD THAT:
A village's denial of a request that land be rezoned from single-family to multiple-family classification, thus preventing the construction of a racially integrated low and moderate income housing development, does not constitute racial discrimination and thus does not constitute a violation of the equal protection clause of the Fourteenth Amendment.
Allegations of racial discrimination does not necessarily result in the use of the strict scrutiny standard by this court..
The courts elaborately discussed the standing of the parties in brining this suit whereby it discussed various types of standing including economic injury and injury to racial minorities (i.e. alleged racial discrimination)
The Court also surmised that official action will not be held unconstitutional solely because it results in a racially disproportionate impact. However, disproportionate impact may be considered in the analysis and is a relevant factor in the analysis.
In determining the intent of the statutory scheme or the challenge decision, a court must examine circumstantial evidence surrounding the decision. The factors that a court may look at include:
whether the scheme bears more heavily on one race than another;
historical background surrounding the decision;
the specific sequence of events that resulted in the challenged scheme;
any procedural and substantive departures from the normal procedures used in approving or denying previous decisions; and
the legislative or administrative history of the decision or action.
Although a pattern of actions may indicate a discrimination, a single discriminatory event is not immune from equal protection inquiry.
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