Village of Arlington Heights v. Metropolitan Housing Development Corp.

1977-01-11

Headline: Suburban rezoning denial is upheld as the Court reverses a lower finding of racial discrimination, making it harder for developers and minority tenants to force rezoning for subsidized integrated housing.

Holding: The Court held that the Village’s refusal to rezone did not violate the Fourteenth Amendment because respondents failed to prove discriminatory intent, and remanded statutory housing claims for further consideration.

Real World Impact:

Makes it harder to challenge local rezoning based solely on racial impact.
Allows municipalities to deny rezoning when no proof of discriminatory intent exists.
Leaves Fair Housing Act claims to be reconsidered by lower courts.

Topics: housing and zoning, racial discrimination in housing, low-income housing, Fair Housing Act

Summary

Background

A nonprofit housing developer (MHDC) sought to rezone a 15-acre parcel in a Chicago suburb from single-family to multi-family to build 190 subsidized townhouses for low- and moderate-income tenants. The Village’s planning board and then the Village Board denied the rezoning after public hearings. MHDC and a few individual residents sued, saying the denial was racially discriminatory under the Constitution and the federal Fair Housing Act. The trial court ruled for the Village, the Court of Appeals reversed, and the Supreme Court took the case on appeal.

Reasoning

The key question was whether the Village’s denial was motivated by racial discrimination, not merely whether it had a racial effect. Relying on the Court’s recent rule that intent must be shown, the majority reviewed the record: the area had been zoned for single-family homes since 1959, hearings followed usual procedures, and the Village’s buffer policy predated the proposal and had been applied elsewhere. The Supreme Court concluded the evidence did not show that racial purpose was a motivating factor, so the Fourteenth Amendment claim failed. The Court reversed the Court of Appeals’ decision on constitutional grounds.

Real world impact

The decision means local zoning denials that have racially disparate effects will not be invalidated unless plaintiffs show discriminatory intent. Developers of federally subsidized integrated housing and prospective minority tenants face a higher burden to prove improper motive. The Court left the Fair Housing Act claims undecided and remanded them for further review, so statutory remedies may still be pursued.

Dissents or concurrances

One Justice urged remanding the whole case to the appeals court to reassess the evidence under the clarified intent standard; another dissented from reversing without remand, criticizing the Court’s reexamination of factual findings.