Warth v. Seldin case brief

Warth v. Seldin case brief summary
422 U.S. 490 (1975)

CASE SYNOPSIS

Petitioners sought review of a decision from the United States Court of Appeals for the Second Circuit, which held that none of the petitioners had standing to prosecute an action claiming that respondents excluded low income persons from living in respondent town in contravention of various constitutional and statutory rights.

CASE FACTS
Petitioners, various organizations and individuals, brought an action against respondent town, and against members of respondent town's planning and zoning boards. Petitioners claimed that respondents' zoning ordinances effectively excluded persons of low and moderate income from living in the town, in contravention of petitioners' constitutional rights and in violation of42 U.S.C.S. §§ 1981, 1982, and 1983. The lower court held that none of the petitioners had standing to prosecute the action.

DISCUSSION

• The court affirmed, holding that the facts alleged failed to support an actionable causal relationship between respondents' zoning practices and petitioners' asserted injury. 
• In contrast to cases where plaintiffs challenged zoning restrictions applied to particular projects that would supply housing within their means, and of which they were intended residents, in this case petitioners were unable to demonstrate that unless relief from the allegedly illegal actions was forthcoming, their immediate and personal interests would be harmed. 
• Thus, the court held that petitioners failed to meet threshold standing requirements and affirmed the judgment below.

CONCLUSION
The judgment below was affirmed based on the court's holding that petitioners failed to meet threshold standing requirements.

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