Village of Arlington Heights v. Metropolitan Housing Development Corp. case brief

Village of Arlington Heights v. Metropolitan Housing Development Corp. case brief summary

429 U.S. 252 (1977)

CASE SYNOPSIS

On writ of certiorari to the United States Court of Appeals for the Seventh Circuit, petitioner sought review of a judgment favorable to respondents that the ultimate effect of petitioner's denial of respondent's request for rezoning was racially discriminatory and that the refusal to rezone violated U.S. Constitutional amendment XIV.

CASE FACTS
Respondents challenged petitioner village's denial of requests for rezoning, alleging that the denials were racially discriminatory and violated U.S. Constitutional amendment XIV. Respondents sought to build low-to-middle income, multiple-family housing subsidized by § 236 of the National Housing Act, 12 U.S.C.S. § 1715z-1. Section 236 required that the subsidized development be racially integrated. Some comments from opponents and supporters addressed the social issue of racial integration; however, many opponents focused on the zoning aspects of respondent's petition since rezoning threatened to cause a measurable drop in property value and since the rezoning was incompatible with the single-family development of the village.

DISCUSSION

• Official action was not unconstitutional solely because it resulted in a racially disproportionate impact. 
• Evidence showed that petitioner focused almost exclusively on the zoning aspects of respondents' petition and the zoning factors on which petitioner relied were not novel criteria in petitioner's rezoning decisions. 
• As such, respondents failed to prove that discriminatory purpose was a motivating factor in petitioner's decision.

CONCLUSION
Th court reversed, holding that respondents failed to carry their burden of proving that discriminatory purpose was a motivating factor in petitioner's denial to rezone. Upon such determination, the constitutional inquiry ended and the lower court's further finding that petitioner's decision carried a discriminatory "ultimate effect" was without independent constitutional significance.