Arlington Heights Case

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Brief Prepared By: Kahla Rosenfeld

Case: Village of Arlington Heights v. Metropolitan Housing Development Corporation, 429 U.S. 252 (1977)
Procedural Overview: Metropolitan Housing Development Corporation applied to the Village of Arlington Heights for rezoning land to build a racially integrated, low and moderate housing project. The request was denied and the respondent, MHDC, sued the petitioner, Arlington Heights, for injunctive and declaratory relief on the grounds of racial discrimination. The District Court ruled in favor of the petitioner; however, on appeal, the United States Court of Appeals for the Seventh Circuit reversed the District Court’s decision. The Petitioner appealed to the United States Supreme Court and writ of certiorari was granted.
Facts: Respondent
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Davis, 426 U.S. 299 (1976) in which the Court decided that an action would not be deemed unconstitutional solely because it results in a racially disproportionate impact, the court held that in order to show a violation of the Equal Protection Clause of the Fourteenth Amendment, proof of racially discriminatory intent or purpose is required.
2.) However, the Court held that an official decision resulting in an unequal impact on any group may provide a starting point, if the burden of proof that discriminatory purpose was a motivating factor in the decision, and a clear pattern of disproportionate impact, which can only be explained by discriminatory intent, is present.
3.) The decision of whether discriminatory intent was a motivating factor inquires a sensitive inquiry into circumstantial and direct evidence, such as comments made by members of the decision making process. After considering such factors, the Court found that the Petitioner’s decision to deny the Respondent’s rezoning request was based on the interest to maintain the area for single-family residential housing, not for discrimination

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