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Village of Arlington Heights v. Metropolitan Housing Development Corp.

Supreme Court of the United States
429 U.S. 252, 97 S.Ct. 555, 50 L.Ed.2d 450 (1977)
ELI5:

Rule of Law:

To establish a violation of the Equal Protection Clause, a plaintiff must prove that a racially discriminatory purpose or intent was a motivating factor in the government's action. A showing of a racially disproportionate impact alone is insufficient to prove such a violation.


Facts:

  • Arlington Heights, a predominantly white suburb of Chicago, had a population of 64,000 residents, only 27 of whom were Black, according to the 1970 census.
  • The Clerics of St. Viator (the Order), a religious group, owned an 80-acre parcel of land zoned for single-family homes (R-3).
  • In 1970, the Order contracted with the Metropolitan Housing Development Corporation (MHDC), a nonprofit developer, to build 190 townhouse units for low- and moderate-income residents on a 15-acre portion of their land.
  • The planned development, Lincoln Green, required the land to be rezoned from single-family (R-3) to multiple-family (R-5).
  • MHDC's proposal specified that it would be subsidized under a federal program requiring an affirmative marketing plan to ensure racial integration.
  • MHDC formally petitioned the Village of Arlington Heights for the necessary rezoning.
  • During public hearings, many opponents focused on the potential for decreased property values and the fact that the project did not fit the Village's buffer policy, which called for multi-family zoning to be located between single-family and commercial districts.
  • The Village Plan Commission recommended denying the request, and the Village Board of Trustees subsequently voted 6-1 to deny the rezoning.

Procedural Posture:

  • Metropolitan Housing Development Corporation (MHDC) and other plaintiffs sued the Village of Arlington Heights in the U.S. District Court for the Northern District of Illinois.
  • After a bench trial, the District Court found for the Village of Arlington Heights, holding that the refusal to rezone was not motivated by racial discrimination.
  • The plaintiffs (appellants) appealed to the U.S. Court of Appeals for the Seventh Circuit.
  • The Court of Appeals reversed, finding that the 'ultimate effect' of the Village's decision was racially discriminatory and therefore violated the Fourteenth Amendment.
  • The Village of Arlington Heights (petitioner) petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.

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Issue:

Does a village's denial of a rezoning request, which has a racially disproportionate impact, violate the Equal Protection Clause of the Fourteenth Amendment absent proof that a racially discriminatory purpose was a motivating factor in the decision?


Opinions:

Majority - Justice Powell

No, the Village's denial of the rezoning request does not violate the Equal Protection Clause because the plaintiffs failed to prove that a discriminatory purpose was a motivating factor in the decision. Citing Washington v. Davis, official action is not unconstitutional solely because it results in a racially disproportionate impact. While such impact is a relevant starting point for inquiry, proof of discriminatory intent is required. The Court outlined several evidentiary sources for determining intent: the historical background of the decision, the specific sequence of events leading up to it, departures from normal procedural or substantive standards, and the legislative or administrative history. Applying these factors, the Court found no evidence of discriminatory purpose. The land had been zoned for single-family use since 1959, the rezoning denial followed normal procedures, and the Village's stated reasons—protecting property values and adhering to its pre-existing 'buffer' zoning policy—were legitimate and consistently applied. The plaintiffs failed to carry their burden of proof, and the disproportionate effect of the decision is without independent constitutional significance.


Dissenting - Justice White

The dissent does not address the merits of the constitutional question. Instead, it argues that the Court should have followed its usual practice when an intervening decision (Washington v. Davis) changes the governing legal standard. The proper course would be to vacate the judgment of the Court of Appeals and remand the case, allowing the lower court to reconsider its ruling in light of the new precedent. The Supreme Court's primary function is not to re-examine evidence and apply a new standard in the first instance, especially when a remand is already required on the separate Fair Housing Act claim.


Concurring in part and dissenting in part - Justice Marshall

This opinion concurs with the majority's articulation of the legal standard for proving an Equal Protection violation but dissents from its decision to apply that standard itself. Like Justice White, Justice Marshall argues that the proper course is to remand the entire case to the Court of Appeals. The lower court is better situated to reassess the evidence under the newly clarified standards from Washington v. Davis and to determine if further proceedings in the District Court are necessary.



Analysis:

This case solidifies the 'discriminatory purpose' requirement established in Washington v. Davis and applies it to the context of zoning and housing. It creates a practical, though not exhaustive, evidentiary framework known as the 'Arlington Heights factors' for courts to use when determining if unconstitutional intent motivated a facially neutral government action. The decision significantly raises the bar for plaintiffs in Equal Protection cases, requiring them to move beyond showing disparate impact and provide circumstantial or direct evidence of the government's subjective motive. This makes it more difficult to challenge zoning ordinances and other government policies that perpetuate segregation or disproportionately harm minority communities.

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