Village of Arlington Heights v. Metropolitan Housing Development Corp.

Brief Fact Summary. The Respondent, Metropolitan Housing Development Corp. (Respondent), applied to the Petitioner, Village of Arlington Heights (Petitioner), for rezoning of a parcel from single family to multi-family, low-income housing. The rezoning was denied and Respondent sued citing racial discrimination.

Synopsis of Rule of Law. Discriminatory effect alone does not render a governmental decision unconstitutional. There must be a motivating discriminatory purpose.

Facts. Respondent wanted to build 190 townhouses on the parcel of land for low and moderate-income tenants. Petitioner denied the request. Respondent brought suit because the decision by Petitioner disproportionately affects racial minorities.

Issue. Does this denial to rezone violate the Equal Protection Clause of the United States Constitution (Constitution)?

Held. No. There is little in the sequence of events of the denial to rezone that leads one to conclude that the decision was racially motivated.

Discussion. There was simply no evidence of discriminatory intent or purpose behind this decision to deny the rezoning. The entire area had been zoned for single-family homes since the late 1950’s. In fact, single-family homes surround the site in question.