Arlington Heights v. Metropolitan Housing Development Corp.
Case Overview
The Metropolitan Housing Development Corporation sought to build racially integrated low-income housing in the Chicago suburb of Arlington Heights, which required a rezoning from single-family to multi-family. The village board denied the rezoning. MHDC and several minority prospective residents sued under the Fair Housing Act and the Equal Protection Clause, arguing the denial was racially discriminatory. The Supreme Court ruled 5-3 that the Equal Protection Clause requires proof of discriminatory intent: disparate racial impact alone is insufficient. The Court articulated a multi-factor test for inferring discriminatory intent from circumstantial evidence, including the historical background of the decision, the sequence of events, departures from normal procedural sequences, and legislative or administrative history. The decision defined discriminatory intent doctrine for Equal Protection Clause claims and remains the controlling framework in civil rights and voting rights cases.
Legal Issues
The Facts
Metropolitan Housing Development Corporation contracted to purchase land in Arlington Heights, a predominantly white Chicago suburb, for the purpose of building racially integrated, federally subsidized low-income townhouses. The land was zoned single-family residential. MHDC requested a rezoning to multi-family, which would allow the project to proceed. After a public hearing, the Arlington Heights Village Board denied the rezoning, citing the general policy against multi-family housing in predominantly single-family neighborhoods and concerns about traffic and project design. The predictable effect of the denial was to exclude low-income and minority residents from the suburb.
The Issue
Whether proof of discriminatory intent is required to establish a violation of the Equal Protection Clause, or whether proof of racially discriminatory effect alone is sufficient Whether the village's zoning decision constituted intentional racial discrimination under either the Equal Protection Clause or the Fair Housing Act
The Rules
Proof of racially discriminatory intent or purpose is required to show a violation of the Equal Protection Clause. Official action will not be held unconstitutional solely because it results in a racially disproportionate impact. Discriminatory intent may be inferred from the totality of the relevant facts, including the historical background, sequence of events, departures from normal procedures, and legislative history.
The Application
The Court found that the plaintiffs had not demonstrated the Village Board acted with racially discriminatory intent in denying the rezoning. The history of the zoning ordinance, the sequence of the board's deliberations, and the stated reasons for denial did not establish that race was a motivating factor in the decision. The Court emphasized that discriminatory intent does not require proof that race was the sole motivating factor, showing it was a motivating factor is enough, but the evidence here fell short of that threshold. The case was remanded for Fair Housing Act analysis under a potentially lower threshold.
The Conclusion
**The Supreme Court held 5-3 that proof of racially discriminatory intent or purpose is required to establish a violation of the Equal Protection Clause; discriminatory impact alone is not sufficient.** The Court remanded for consideration of the Fair Housing Act claim. Justice Powell's majority opinion provided a multi-factor framework for inferring discriminatory intent from circumstantial evidence: (1) the historical background of the decision; (2) the sequence of events leading up to the challenged decision; (3) departures from the normal procedural sequences; (4) departures from normal substantive criteria; and (5) the legislative or administrative history, including contemporaneous statements by members of the decision-making body.
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