Town of Huntington v. Huntington Branch
Headline: Court affirms appeals court and blocks a town zoning rule that confined private multifamily housing to a minority area, making it easier for developers and low-income minorities to seek housing outside that neighborhood.
Holding: The Court affirmed the appeals court’s decision that the town’s ordinance, which limited private multifamily housing to the urban renewal (largely minority) area, had a discriminatory effect and lacked an adequate justification.
- Requires the town to remove the zoning limit on private multifamily projects.
- Makes it easier for developers to propose multifamily housing outside the minority area.
- May increase low-income minorities’ access to rental housing outside the renewal zone.
Summary
Background
The dispute involves the town of Huntington, New York, a community of about 200,000 residents that is roughly 95% white and less than 4% black, with most Black residents clustered in a few census tracts. In the 1960s the town adopted a zoning rule (§ 198-20) that allowed private multifamily housing only within the designated urban renewal area, where a large share of minority residents live. Housing Help, Inc., a private developer seeking to build multifamily housing in a 98% white neighborhood, asked the town to amend the rule and to rezone a particular site; the board refused. HHI, the local NAACP branch, and two Black low-income residents sued under the civil-rights law that bans housing discrimination (Title VIII).
Reasoning
The core question for the courts was whether the zoning rule had a discriminatory effect by making low-cost multifamily housing available only in the largely minority urban renewal area. The Second Circuit held that a plaintiff can prove a Title VIII violation by showing discriminatory impact, found that the ordinance perpetuated segregation, and required the town to justify the rule and show no less discriminatory alternatives. The town’s stated reason — encouraging investment in the renewal area — was held inadequate. The Supreme Court limited its review to the part of the case striking the zoning restriction, noted appellants had accepted the disparate-impact framework for that issue, and, without adopting every detail of the lower court’s analysis, agreed disparate impact was shown and the justification was insufficient, so it affirmed.
Real world impact
The ruling means the town must remove the restriction that confined private multifamily projects to the urban renewal area, which makes it easier for private developers to propose multifamily rental housing outside the minority neighborhood and may improve access for low-income minority households. The Court did not review the separate claim about rezoning the specific site, so that decision remains unresolved in the lower courts.
Dissents or concurrances
Three Justices (White, Marshall, and Stevens) would have noted probable jurisdiction and set the case for oral argument rather than issuing this per curiam ruling.
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