Arlington Heights v. Metropolitan Housing Development Corp
Arlington Heights v. Metropolitan Housing Development Corp. is a significant Supreme Court case from 1977 that addresses issues of racial discrimination and zoning laws. The case arose when a nonprofit organization sought to build affordable housing in a predominantly white suburb of Chicago, aiming to foster racial integration. However, the local board of trustees denied the request to rezone the area for multi-family dwellings, effectively halting the project.
The federal appeals court found that this denial was discriminatory under the Fourteenth Amendment. However, the Supreme Court reversed this decision, emphasizing that proving a violation of constitutional rights requires evidence of discriminatory intent. Justice Lewis F. Powell, Jr. articulated that the plaintiffs did not adequately demonstrate that racial discrimination influenced the village's decision. This ruling highlights the complexities of legal standards regarding discrimination and the challenges faced in efforts to promote integration through housing policies. The case remains a critical reference point in discussions about zoning, housing equity, and racial justice in America.
Arlington Heights v. Metropolitan Housing Development Corp.
Date: January 11, 1977
Citation: 429 U.S. 252
Issue: Racial discrimination by a governmental agency
Significance: The Supreme Court reaffirmed the principle that a governmental policy will not be judged unconstitutional solely because it has a disproportionate impact on a particular race.
A nonprofit developer wanted to construct low- and moderate-income housing units in a largely white suburb of Chicago. A major goal of the project was to promote racial integration in the community. The suburb’s board of trustees refused to rezone the region for multiple-family dwellings, thus killing the project. The federal court of appeals ruled that the denial of rezoning violated the Fourteenth Amendment because its “ultimate effect” was discrimination against racial minorities. By a 7-1 vote, the Supreme Court reversed the lower court’s ruling. Based on the recent precedent, Washington v. Davis (1976), Justice Lewis F. Powell, Jr., explained that proof of a “racially discriminatory intent” was necessary in order to establish a constitutional violation. From the official minutes and other evidence of the case, Powell concluded that the challengers had “simply failed to carry their burden of showing that discriminatory purpose was a motivating factor in the Village’s decision.”
