Metropolitan Housing Development Corp. v. Village of Arlington Heights

The Clerics of St. Viator, a religious order, owned 80 acres of property in the Chicago suburb of the Village of Arlington Heights (village) (defendant). The Clerics decided to build low- and moderate-income housing on its land with the help of Metropolitan Housing Development Corp. (MHDC) (plaintiff), a nonprofit developer experienced in building low-cost housing through obtaining federal subsidies under § 236 of the National Housing Act. Because the land was zoned for single-family homes, MHDC petitioned the village for rezoning to allow for connected townhouse units. The petition described the plan for affordable housing and how federal subsidies required racially integrated housing. In contrast to the rest of Chicago, the village was almost totally White, and 40 percent of those eligible for federal housing subsidization were not White. The village board of trustees voted to deny the petition and asserted the housing could be built on other properly zoned land. MHDC and three Black individuals sued in federal district court, alleging the rezoning refusal violated equal protection and the Fair Housing Act, specifically 42 U.S.C. § 3604(a), prohibiting denying housing because of race, and 42 U.S.C. § 3617, prohibiting interference with exercising rights under the Fair Housing Act. The Supreme Court ultimately rejected the equal-protection claim—requiring discriminatory intent, not mere discriminatory effect. The case was remanded to the court of appeals for a determination of the Fair Housing Act claim, which the district court had not addressed.