Arlington Heights v. Metropolitan Housing Corp.

The case established a key standard for determining when the Equal Protection Clause of the Fourteenth Amendment was violated due to racial discrimination in housing. The simple fact that a decision may result in unequal effects on different racial groups was not sufficient evidence to prove racial discrimination. Those contesting an action on such grounds must also prove an intent to discriminate in the decision-making process. Fair housing proponents claimed the decision perpetuated deceptive segregation decisions made through the process of urban zoning.

Urban zoning gained substantial acceptance in the United States shortly after the beginning of the twentieth century. Zoning is a form of police power provided by the states to their local municipal governments. By limiting certain personal freedoms, communities can better provide for the health, safety, and welfare of their residents. Importantly, zoning regulations must be reasonable and conform with constitutional guarantees of equal protection and due process of the law. Despite being born from good ideals, zoning was frequently used as a means to keep people of lower social status out of certain areas to maintain market values of property. This form of zoning was labeled exclusionary zoning and was condemned by many. In 1968 Congress passed the Fair Housing Act, the first open housing act of the twentieth century. The act supported the notion that citizens should be free to live wherever they choose and can afford. The law prohibited discrimination in the sale and renting of certain types of housing on the basis of race and religion. The Supreme Court, also in 1968, ruled that federal law against housing discrimination applied to all housing. Despite the 1968 law and Court ruling, cases of housing discrimination against African American citizens pervasively continued.