Arlington Heights v. Metropolitan Housing Corp.

Ruling in favor of Metropolitan, the appeals court in July of 1977 ruled that the refusal to rezone violated the Fair Housing Act because the effect was discriminatory even though there may have been no intent. The court held that actions predictably perpetuating racial discrimination were as harmful as intentional discrimination. Besides, the goal of the Fair Housing Act was to racially integrate housing throughout the nation.

The Arlington Heights decision established the standard for determining racial discrimination in housing by applying the standard established in Davis. Governmental actions should not be considered discriminatory solely on the basis of unequal effects. Proof of the intent to discriminate was also necessary. The evidence to be considered included the effect of the official action. Did it weigh more heavily on one minority group than another? Secondly, the historical background of the decision was to be reviewed to determine if the series of official actions were intentionally malicious. Thirdly, did the decision-makers deviate from the normal process. Lastly, any deviations would be assessed to determine if any important facts to the specific case could strongly favor a different resulting decision quite different than the one reached. Proof of such a racially discriminatory intent was required to establish a violation of the Equal Protection Clause.

Fair housing advocates criticized the decision. They believed the Court perpetuated the abuse of zoning powers maintaining status quo segregation and social class distinctions. Such exclusionary zoning hardly served the general welfare of the communities or the nation, they contended. However, the Arlington Heights decision perpetuated the Court's reluctance to rule against local zoning decisions.