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Trafficante v. Metropolitan Life Insurance

Supreme Court of the United States
1972 U.S. LEXIS 4, 409 U.S. 205, 34 L. Ed. 2d 415 (1972)
ELI5:

Rule of Law:

The term 'person aggrieved' under § 810(a) of the Civil Rights Act of 1968 (Fair Housing Act) is defined broadly to include any person who claims injury from a discriminatory housing practice, which encompasses current tenants of a large housing complex who allege they have been injured by the loss of benefits from interracial association.


Facts:

  • Two tenants, one black and one white, resided in the Parkmerced apartment complex in San Francisco.
  • The complex housed approximately 8,200 residents, of whom less than 1% were black.
  • The tenants alleged that the owner of Parkmerced engaged in discriminatory housing practices against nonwhite rental applicants.
  • These alleged practices included manipulating waiting lists, using discriminatory acceptance standards, and making it known to nonwhites that they were not welcome.
  • The two tenants claimed they were personally injured by these practices against third parties.
  • The alleged injuries included the loss of social and professional benefits from living in an integrated community and suffering from the stigma of living in a 'white ghetto'.

Procedural Posture:

  • Two tenants filed complaints with the Secretary of Housing and Urban Development (HUD) under the Civil Rights Act of 1968.
  • After a state agency deferred back to HUD and HUD was unable to obtain voluntary compliance, the tenants filed a civil action in the United States District Court.
  • The District Court, a court of first instance, dismissed the complaint, holding that the tenants lacked standing to sue.
  • The tenants, as appellants, appealed to the United States Court of Appeals for the Ninth Circuit.
  • The Court of Appeals, an intermediate appellate court, affirmed the District Court's dismissal.
  • The tenants, as petitioners, were granted a writ of certiorari by the United States Supreme Court.

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Issue:

Does the term 'person aggrieved' under § 810(a) of the Civil Rights Act of 1968 grant standing to sue to current tenants of a housing complex who allege they were injured by the owner's discriminatory rental practices against nonwhite applicants?


Opinions:

Majority - Justice Douglas

Yes. Standing under § 810(a) of the Civil Rights Act of 1968 extends to all who are injured by racial discrimination in the management of housing facilities, not just the direct objects of the discrimination. The statute defines a 'person aggrieved' broadly as '[a]ny person who claims to have been injured by a discriminatory housing practice.' The tenants in this case alleged a concrete injury-in-fact, namely the loss of important benefits from interracial associations, which distinguishes their claim from abstract grievances. This broad interpretation is supported by the consistent construction of the enforcing agency (HUD), the legislative intent to create 'truly integrated and balanced living patterns,' and the Act's enforcement structure, which relies on 'private attorneys general' to vindicate a policy of the highest national priority.


Concurring - Justice White

Yes. While it would be difficult to find a case or controversy under Article III of the Constitution based on these facts alone, Congress has the authority to create statutory rights and grant standing to sue to enforce them. The Civil Rights Act of 1968 explicitly gives persons in the petitioners' position the right to complain to an agency and to sue in court. Therefore, the Court should sustain the statute's extension of standing to these petitioners, as Congress has effectively defined the injury and created a cause of action.



Analysis:

This decision significantly broadened the interpretation of standing under the Fair Housing Act, establishing that standing is not limited to the direct victims of discrimination. By recognizing the loss of interracial associations as a cognizable injury, the Court empowered existing tenants, civil rights 'testers,' and community organizations to challenge discriminatory housing practices. This ruling fortified the Act's enforcement mechanism by confirming the vital role of 'private attorneys general' in achieving the statute's goal of integrated housing, thereby making it more difficult for landlords to maintain segregated communities.

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