Brief Fact Summary. The Metropolitan Housing Development Corporation (Respondent) applied to the Village of Arlington Heights (Petitioner) for rezoning of a 15 acre parcel from single-family residential to multi-family residential, intending to build federally subsidized low to moderate income housing. The request was denied and Respondent sued for injunctive and declaratory relief, claiming that the effect of the denial of rezoning was discriminatory in nature and thus violative of the Fourteenth Amendment and the Fair Housing Act of 1968, 42 U.S.C. Section:3601, et. seq.
Synopsis of Rule of Law. Official action will not be held unconstitutional solely because it results in a racially disproportionate impact.
Issue. Was the denial of the rezoning application unconstitutionally or statutorily discriminatory?
Held. The Court found that the Respondents failed to meet their burden of proving that discriminatory purpose was a motivating factor in the Petitioner’s decision, but the court of appeals did not decide whether the Respondent’s have stated a claim under the Fair Housing Act. Reversed and Remanded.
The Court cited its prior decision in Washington v. Davis, 426 U.S.. 229 (1976), which stood for the rule that official action will not be held unconstitutional solely because it results in a racially disproportionate impact. Proof of racially discriminatory intent or purpose is required to show a violation of the Equal Protection Clause of the Fourteenth Amendment.
Determining whether discriminatory purpose was a motivating factor demands a sensitive inquiry into such circumstantial and direct evidence as may be available. The impact of the official decision may provide an important starting point.
In this case the Court found that the decision to deny rezoning was based on a desire by the Petitioner to maintain the area as single-family residential housing, and not for discriminatory motive.
The burden of proof is on the plaintiff in these cases to prove that discriminatory purpose was a motivating factor in the decision.
The case was remanded to determine whether the Respondents had stated a claim of discrimination under the Fair Housing Act statute.
Discussion. In cases without some evidence of racially discriminatory intent, the mere fact that the decision of a governmental agency affects race will not be enough to show a violation of the Fourteenth Amendment’s Due Process Clause.