Village of Arlington Heights v. Metropolitan Housing Development
SCOTUS - 1977
- MHDC asked Arlington Heights for the rezoning of a 15-acre parcel from single-family to multiple-family classification.
- MHDC planned to build 190 clustered townhouse units for law and moderate-income tenants.
- Arlington Heights denied the rezoning request.
- MHDC brought suit alleging that the denial was racially discriminatory.
- SCOTUS held that the denial of rezoning was not unconstitutional.
- How can a plaintiff prove discriminatory intent in an Equal Protection Clause case?
- Determining whether discriminatory purpose was a motivating factor demands a sensitive inquiry into circumstantial and direct evidence of intent as may be available.
- The impact of the official action.
- A clear pattern, unexplainable on grounds other than race.
- The historical background of the decision.
- The specific sequence of events leading up to the challenged decision. (Departures from normal procedural/substantive sequence)
- Legislative or administrative history.
- The impact of Arlington Height's decision does bear more heavily on racial minorities.
- However, there is no evidence of discriminatory purpose.
- There is little about the sequence of events leading up to the decision that would spark suspicion.
- The rezoning request progressed according to usual procedures.