## Facts

- A town zoning ordinance permitted private multifamily housing only within an “R-3M Garden Apartment Special District” located in an urban renewal area of Huntington Station.
- Huntington Station had a substantially higher minority population than the town overall; the remainder of the town was predominantly white and largely zoned for single-family residences.
- Plaintiffs (civil-rights and housing organizations and a certified class of Black, Hispanic, and low-income residents) sought to build Matinecock Court, a subsidized, integrated, multifamily rental development in a predominantly white neighborhood.
- The proposed site was zoned for single-family homes, requiring either a town-wide change allowing multifamily housing or rezoning of the parcel.
- The Town Board refused to amend the zoning code or rezone the Matinecock Court parcel.
- After a bench trial, the district court entered judgment for the town; on appeal, plaintiffs pursued only Fair Housing Act claims.

## Issues

1. Whether a zoning scheme that confines private multifamily housing to a small, predominantly minority area violates the Fair Housing Act because of its discriminatory effect on minorities.
2. Whether the town’s refusal to rezone a site outside that area for a subsidized, integrated multifamily project violates the Fair Housing Act.

## Decision

- The Second Circuit reversed.
- The court held that the zoning ordinance violated the Fair Housing Act because it had a significant disparate impact on Black and Hispanic residents by restricting realistic lower-cost housing opportunities to a minority-concentrated area and perpetuating segregation.
- The court held that the refusal to rezone the Matinecock Court site likewise violated the Fair Housing Act because it continued exclusion of minority and low-income households from predominantly white neighborhoods without sufficient justification.
- The court ordered injunctive relief requiring the town to eliminate the zoning limitation confining private multifamily housing to the Huntington Station urban renewal area and to rezone the Matinecock Court parcel to permit the project.

## Legal Principles

- Under the Fair Housing Act, a plaintiff may establish liability by showing that a facially neutral policy actually or predictably results in racial discrimination (disparate impact); proof of discriminatory intent is not required for such a claim.
- Once plaintiffs make a prima facie showing of discriminatory effect, the burden shifts to the defendant to prove the policy is supported by legitimate, bona fide governmental interests and that those interests cannot be served by less discriminatory alternatives.
- Zoning measures that perpetuate segregation or exclude minorities from housing opportunities can violate the Fair Housing Act when their discriminatory effects are substantial and asserted planning interests are not adequately supported or can be met through narrower tools.

## Conclusion

The court held that the town’s restriction of private multifamily housing to a predominantly minority area, and its denial of rezoning for an integrated subsidized development in a predominantly white area, produced unlawful discriminatory effects under the Fair Housing Act and required injunctive correction.


Huntington Branch, NAACP v. Town of Huntington, 844 F.2d 926 (2d Cir. 1988)