## Facts

- Black public-housing tenants and applicants in Chicago sued the Chicago Housing Authority (CHA), alleging CHA intentionally selected family public-housing sites to avoid placing Black families in white neighborhoods, producing racially segregated projects.
- The same plaintiffs sued the U.S. Department of Housing and Urban Development (HUD), alleging HUD financed and otherwise supported CHA’s discriminatory siting and housing program.
- The district court entered summary judgment against CHA on an evidentiary record, finding constitutional and statutory violations and ordering local remedial action.
- The district court initially dismissed the action against HUD, but the Seventh Circuit reversed, holding HUD had committed constitutional and statutory violations by sanctioning and assisting CHA’s discriminatory program.
- On remand, the consolidated cases proceeded to remedy; plaintiffs sought “metropolitan area relief” extending beyond Chicago into the surrounding suburban housing market.
- The district court rejected metropolitan relief and adopted an order limiting corrective action to the City of Chicago.
- The Seventh Circuit reversed and remanded for additional evidence and further consideration of metropolitan relief.
- The Supreme Court granted certiorari limited to whether metropolitan-area relief against HUD was impermissible as a matter of law, including under Milliken v. Bradley.

## Issues

1. Whether a federal court lacks authority, as a matter of law, to order a metropolitan-area housing remedy against HUD for its role in discriminatory public-housing practices within Chicago.
2. Whether Milliken v. Bradley categorically bars remedial orders that operate beyond municipal boundaries absent proof of wrongdoing by suburban governmental entities.

## Decision

- The Supreme Court affirmed the Seventh Circuit.
- The Court held that metropolitan-area relief was not impermissible as a matter of law.
- Milliken did not create a per se rule preventing remedies extending beyond the municipality where the violations occurred.
- The case was properly remanded for additional evidence and consideration of an appropriate metropolitan-wide remedy against HUD.

## Legal Principles

- Federal courts may craft equitable remedies reaching beyond municipal boundaries when necessary to address the violation and its effects.
- Milliken limits interdistrict remedies where there is no interdistrict violation by the outlying districts; it does not bar broader relief when the liable defendant’s conduct and the effects of the violation extend beyond city lines.
- In public-housing discrimination cases, the relevant geographic scope for relief may be the housing market affecting the plaintiffs’ realistic housing opportunities, not a city’s political boundaries.
- A metropolitan remedy directed at HUD can be structured to operate through HUD’s own programs and contracting authority and need not impose direct obligations on unwilling suburban jurisdictions, while leaving local land-use controls intact.

## Conclusion

The Court held that, because HUD was found to have participated in unconstitutional and unlawful racial discrimination in public housing, a court may consider and order metropolitan-area relief designed to remedy the broader effects of that discrimination, and Milliken does not categorically restrict such housing remedies to city boundaries.


Hills v. Gautreaux, 425 U.S. 284 (1976)