Charleston Housing Authority v. United States Department of Agriculture

The Charleston Housing Authority (the housing authority) (defendant) developed a revitalization plan that included demolishing 50 low-income apartment units occupied primarily by Black tenants (plaintiffs). The tenants sued the housing authority, seeking an injunction to prevent the implementation of the plan. The tenants alleged that implementation of the plan would result in a disparate impact based on race and offered statistical evidence to support their allegation. The housing authority argued that implementation of its plan was necessary to reduce the density of low-income housing and to eliminate a housing design that contributed to drug use and criminal activity. The district court found that the housing authority’s justifications were pretextual. Specifically, the court determined that the housing authority had misrepresented the actual density of the apartment units in question, and it found that the statistical evidence presented by the housing authority did not demonstrate that the apartments had a significant crime problem. The district court enjoined the housing authority’s implementation of the plan, and the housing authority appealed. On appeal, the housing authority argued that its proposed plan was a legitimate legislative action with which the district court’s injunction had impermissibly interfered.