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Discriminatory results? It might not be discriminatory intent. (Village of Arlington Heights v. Metropolitan Housing Development Corp.)

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Village of Arlington Heights v. Metropolitan Housing Dev. Corp.

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In the early 1970s, the Metropolitan Housing Development Corporation (MHDC) planned to build an apartment complex in the Chicago suburb of Arlington Heights. The MHDC wanted the development to be racially integrated and available to lower-income tenants.

To build the apartment complex, the MHDC needed to apply for rezoning. At the time, Arlington Heights was middle class and predominantly white, and many of its residents were hostile toward the development. Other homeowners were concerned about the development’s impact on property values, particularly because the development was contrary to the town’s zoning layout.

The zoning board refused to rezone the land, and the MHDC sued the city in federal court. The MHDC argued that the board’s ruling was discriminatory and thus violated the Equal Protection Clause.

Ultimately, the case wound up before the United States Supreme Court, in Village of Arlington Heights v. Metropolitan Housing Dev. Corp., 429 U.S. 252 (1977). The Court concluded that discriminatory results alone are insufficient to support a Fourteenth Amendment violation.

According to the Court, only state action with discrimination as a “motivating factor” violates the Equal Protection Clause. Because the MHDC could not show that discrimination was a motivating factor in the zoning board’s decision, the zoning board’s decision could stand.

Village of Arlington Heights remains an important Supreme Court case on the difference between discriminatory impact and discriminatory intent.

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