Brief Fact Summary.
MHDC wanted to rezone a parcel of land. Arlington denied its application, and MHDC filed a lawsuit in federal court, claiming that Arlington violated the Fourteenth Amendment and the Fair Housing Act of 1968.
Synopsis of Rule of Law.
A plaintiff claiming an equal protection violation must show both discriminatory impact and discriminatory intent.
Rarely can it be said that a legislature or administrative body operating under a broad mandate made a decision motivated solely by a single concern, or even that a particular purpose was the dominant or primary one.View Full Point of Law
MHDC applied to Arlington to rezone a 15-acre parcel of land from single-family to multiple-family. It planned to use federal funds to build low- and moderate-income townhomes. Arlington denied the application, and MHDC filed a lawsuit in federal court, claiming that Arlington violated the Fourteenth Amendment and the Fair Housing Act of 1968.
Did the Village of Arlington violate the Fourteenth Amendment in denying MHDC’s rezoning application?
No, it did not. The denial was constitutional.
Washington v. Davis (1977) held that actions are not unconstitutional under the Fourteenth Amendment just because it has a racially disproportionate impact; a plaintiff also needs to show discriminatory intent or purpose. To find intent or purpose, there needs to be an evaluation of circumstantial and direct evidence. Discriminatory impact, history, and legislative history can be circumstantial evidence.
In this case, the impact bears more heavily on racial minorities, but there is little other evidence to suggest it was discriminatory intentionally. Plaintiffs failed to meet the burden of proving that discriminatory intent was a motivating factor in the Village’s decision.