## Facts

- Black residents of Dade City, Florida, sued the city and city officials under 42 U.S.C. § 1983, alleging racial discrimination in municipal services.
- The challenged services were street paving, street resurfacing and maintenance, and storm-water drainage facilities.
- Dade City was historically divided into predominantly Black and predominantly white residential areas; plaintiffs lived in the Black residential area.
- After a bench trial, the district court found large, sustained disparities: the city systematically devoted greater resources to the white community, leaving the Black community with substantially inferior paving, maintenance, and drainage.
- In measuring disparities, the district court included (i) streets in the Black residential area that were annexed during the litigation because they functioned as part of that community before formal annexation, and (ii) certain state- or county-owned streets in the white area because the city regularly requested and coordinated maintenance and improvements for them.
- The district court also relied on historical and documentary evidence showing a legislative and administrative history of racial discrimination in municipal services and planning.
- The district court concluded the city acted with discriminatory intent in violation of the Equal Protection Clause and entered judgment for plaintiffs; the city appealed.

## Issues

1. Whether the district court clearly erred in finding intentional racial discrimination in the provision of paving, street resurfacing and maintenance, and storm-water drainage services, in violation of the Equal Protection Clause.
2. Whether the district court erred by including (a) recently annexed streets in the Black residential area and (b) state/county-owned streets in the white area in its disparity analysis.
3. Whether statistical disparities combined with historical and documentary evidence were sufficient to support an inference of purposeful discrimination rather than disparate impact alone.

## Decision

- The Eleventh Circuit affirmed the judgment for plaintiffs.
- The court held the district court’s finding of intentional discrimination was not clearly erroneous.
- The court upheld the methodology that treated annexed streets as part of the Black community for purposes of the service comparisons.
- The court upheld counting state/county-owned streets in the white area where the city regularly sought and relied on intergovernmental maintenance and improvements for those streets.

## Legal Principles

- An Equal Protection claim challenging allocation of public services requires proof of purposeful racial discrimination; disparate impact alone is insufficient.
- Discriminatory intent may be inferred from a clear, sustained pattern not reasonably explained on nonracial grounds, and from contextual evidence such as historical background and administrative or legislative practice (as in the Arlington Heights framework).
- Appellate review of a district court’s factual findings, including discriminatory intent, is for clear error; where the record supports the trial court’s permissible view of the evidence, the findings are not disturbed.
- In assessing service disparities, courts may consider functional, real-world delivery of services, including the effects of annexation decisions and a city’s role in obtaining state/county maintenance for streets used by residents.

## Conclusion

The Eleventh Circuit left in place the district court’s determination that Dade City intentionally discriminated against Black residents in basic infrastructure services and that the trial court permissibly relied on statistical disparities, historical evidence, and service-delivery realities when inferring discriminatory intent under the Equal Protection Clause.


Ammons v. Dade City, 783 F.2d 982 (11th Cir. 1986)