Monday, November 25, 2013

Town of Huntington v. Huntington Branch, NAACP, case brief

Town of Huntington v. Huntington Branch, NAACP, case brief summary
488 U.S. 15 (1988)

Appellee local branch of the National Association for the Advancement of Colored People (NAACP) filed a complaint against appellant town alleging, inter alia, that the town's zoning ordinance violated Title VIII of the Civil Rights Act of 1968. The district court rejected the Title VIII claims, the United States Court of Appeals for the Second Circuit reversed, and the town sought review.

The town had a zoning classification permitting private construction of multifamily housing projects only in the town's urban renewal area where the majority of residents were minorities. A private developer's request that the zoning code be amended to permit multifamily rental construction in a predominantly white section of town was rejected. The NAACP brought suit alleging that the town had violated Title VIII by refusing to amend the zoning code and by refusing to rezone the proposed building site.

The district court rejected the NAACP's claims. The court of appeals reversed as to both claims, holding that the NAACP had established a prima facie case of discriminatory impact, which the town had failed to rebut. It ordered the town to strike the zoning limitation and to rezone the project site. The town appealed.


  • The U.S. Supreme Court affirmed. 
  • The Court declined to review the refusal to rezone the project site as that portion of the case did not implicated the Court's mandatory jurisdiction. 
  • Without endorsing the disparate-impact test, the Court found that disparate impact was shown and that the justification proffered by the town to rebut the prima facie case was inadequate.

The judgment of the court of appeals was affirmed.

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