Village of Arlington Heights v. Metropolitan Housing Development Corp., 429 U.S. 252 (1977)
Village of Arlington Heights v. Metropolitan Housing Development Corp.
Does the denial of a rezoning request, which effectively prevented the construction of racially integrated housing, constitute a violation of the Equal Protection Clause of the Fourteenth Amendment due to alleged discriminatory intent?
To prove a violation of the Equal Protection Clause on the grounds of racial discrimination, the plaintiff must show that the decision was made with a discriminatory purpose. An intent to discriminate must be proved, as mere disparate impact is insufficient.
The U.S. Supreme Court held that there was no sufficient evidence to prove that the denial of the rezoning request by the Village of Arlington Heights was racially motivated or that it was intended to discriminate against potential minority residents.
This case is significant because it shapes the standard for proving discriminatory intent in equal protection claims. It underscores that showing discriminatory impact is not enough; plaintiffs must provide evidence of a discriminatory purpose. This sets a higher threshold and has profound implications for cases involving allegations of racial discrimination, particularly in contexts where policy decisions could have a disparate impact on different demographic groups.