Village of Arlington Heights v. Metropolitan Housing Development
SCOTUS - 1977
Facts
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.
Procedural History
SCOTUS held that the denial of rezoning was not unconstitutional.
Issues
How can a plaintiff prove discriminatory intent in an Equal Protection Clause case?
Holding/Rule
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.
Reasoning
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.
