Arlington Heights v. Metropolitan Housing Development Corp.
Citation and Court
429 U.S. 252 (1977) — Supreme Court of the United States
Facts
The Metropolitan Housing Development Corporation sought to rezone a parcel of land in Arlington Heights, Illinois, from single-family to multi-family zoning so it could build racially integrated low-cost housing. The village denied the rezoning request, maintaining the existing single-family zoning. MHDC and minority plaintiffs sued, alleging the refusal was racially motivated in violation of the Equal Protection Clause.
Issue
Whether a facially neutral government action (zoning decision) violates the Equal Protection Clause when it has a racially discriminatory effect but plaintiffs cannot prove discriminatory intent was a motivating factor.
Holding
A facially neutral law or government action does not violate the Equal Protection Clause based on disparate racial impact alone; plaintiffs must prove that discriminatory purpose was a motivating factor in the decision. Here the plaintiffs failed to demonstrate discriminatory intent, so the zoning decision stands.
Rule / Doctrine
Discriminatory intent requirement: equal protection challenges to facially neutral government action require proof that discriminatory intent or purpose was a motivating factor in the decision. Relevant evidence of intent includes: the discriminatory impact of the official action, the historical background of the decision, the sequence of events leading up to the decision, departures from normal procedures, and legislative or administrative history.
Significance
Arlington Heights is the foundational case establishing that disparate impact alone is insufficient to establish an Equal Protection Clause violation — a holding confirmed and extended in Washington v. Davis (1976). The multi-factor framework for inferring discriminatory intent remains the governing standard for facially neutral laws challenged on equal protection grounds.