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
- Whether the developer and individual plaintiffs had Article III standing to challenge the rezoning denial.
- Whether a facially neutral zoning decision that disproportionately burdens racial minorities violates the Equal Protection Clause absent proof of discriminatory purpose.
- 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.
Legal Principles
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Official action is not unconstitutional under the Equal Protection Clause solely because it has a racially disproportionate impact; discriminatory purpose is required.
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Disparate impact may be relevant evidence, but it is not dispositive unless it reflects a clear pattern unexplainable on grounds other than race.
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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.
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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.