Vill. of Arlington Heights v. Metro. Hous. Dev. Corp., 429 U.S. 252 (1977)

Facts

  • A religious order owned an 80-acre tract in Arlington Heights, Illinois, surrounded by single-family homes, and agreed to sell roughly 15 acres to a nonprofit developer to build low- and moderate-income housing.
  • The proposed development (Lincoln Green) contemplated about 190 units in multiple two-story buildings and federal financing under § 236 of the National Housing Act.
  • The sale and development depended on the Village rezoning the parcel from single-family to a multi-family classification (R-5) and obtaining federal assistance.
  • The Village generally used R-5 zoning sparingly and largely as a buffer between single-family areas and commercial or industrial districts; the proposed site did not adjoin such districts.
  • During public hearings, participants raised conventional land-use concerns (density, traffic, property values, neighborhood character), and some comments referenced that the project would likely be racially integrated.
  • The Village Plan Commission recommended denial; the Village Board adopted that recommendation and refused to rezone.
  • The developer and individual Black plaintiffs sued for declaratory and injunctive relief, alleging violations of the Fourteenth Amendment Equal Protection Clause and the Fair Housing Act of 1968.
  • The district court found the denial rested on planning concerns rather than racial discrimination and entered judgment for the Village; the court of appeals reversed based on the decision’s disproportionate racial effects.

Issues

  1. Whether the developer and individual plaintiffs had Article III standing to challenge the rezoning denial.
  2. Whether a facially neutral zoning decision that disproportionately burdens racial minorities violates the Equal Protection Clause absent proof of discriminatory purpose.
  3. Whether, if the constitutional claim fails, the Fair Housing Act claim remains for further adjudication under potentially different standards.

Decision

  • The Court held the developer and at least one individual plaintiff had standing based on concrete injuries traceable to the rezoning denial and redressable by relief.
  • The Court reversed the judgment finding an Equal Protection Clause violation, holding that disparate impact alone does not establish unconstitutional racial discrimination.
  • The Court concluded plaintiffs failed to prove the rezoning denial was motivated by a discriminatory racial purpose.
  • The Court remanded for further proceedings on the Fair Housing Act and any unresolved issues.
  • Official action is not unconstitutional under the Equal Protection Clause solely because it has a racially disproportionate impact; discriminatory purpose is required.

  • Disparate impact may be relevant evidence, but it is not dispositive unless it reflects a clear pattern unexplainable on grounds other than race.

  • Discriminatory purpose may be shown through a fact-specific inquiry into circumstantial and direct evidence, including:

    • the action’s impact;
    • the historical background of the decision;
    • the sequence of events leading to the decision;
    • departures from normal procedural or substantive decisionmaking;
    • legislative or administrative history, including contemporaneous statements and official records.
  • A finding of no constitutional violation does not necessarily resolve statutory housing-discrimination claims, which may proceed under different liability standards.

Conclusion

The Court required proof that racial discrimination was a motivating factor to establish an equal protection violation from a facially neutral rezoning denial, rejecting liability based only on disparate impact, and sent the case back to consider the Fair Housing Act claim under its own standards.