Village of Arlington Heights v. Metropolitan Housing Development Corp.

Brief Fact Summary.

Metropolitan Housing Development Corporation sued the Village of Arlington Heights alleging that the Village’s denial of its rezoning request was racially discriminatory in violation of the Fourteenth Amendment.

Synopsis of Rule of Law.

Official action will not be held unconstitutional solely because it results in a racially disproportionate impact.

Facts.

In 1971 respondent Metropolitan Housing Development Corporation (MHDC) applied to petitioner, the Village of Arlington Heights for the rezoning of a 15-acre parcel from single-family to multiple-family classification. MHDC planned to build clustered townhouse units for low and moderate-income tenants. The Village denied the rezoning request. MHDC sued alleging that the denial was racially discriminatory. Opponents of the rezoning argued that the area always had been zoned single-family and the neighboring citizens had built in reliance on that classification and that rezoning threatened to cause a measurable drop in property value of neighboring sites.

Issue.

Does the denial by the Village of the petitioner’s request for the rezoning of a 15-acre parcel from single-family to multiple-family classification violate the Constitution?

Held.

No, because the evidence presented by the MHDC does not warrant overturning the findings of the court below. Respondents failed to carry their burden of proving that discriminatory purpose was a motivating factor in the Village’s decision. The denial of the respondents’ proposal had no racially discriminatory purpose and its decision served the Village’s compelling interests.

Discussion.

The historical background of the decision or policy by the Village is one evidentiary source, particularly if it reveals a series of official actions taken for invidious purposes. The specific sequence of events leading up to the challenged decision also may shed some light on the decisionmaker’s purposes. Here, there has been reliance by some neighboring property owners on the maintenance of single-family zoning in the vicinity and the Village originally adopted its buffer policy long before MHDC entered the picture and has applied the police too consistently for the court to infer discriminatory purpose from its application. Further, MHDC called one member of the Village Board to the stand at trial, but nothing in her testimony supported an inference of invidious purpose.