MHANY Management, Inc. v. County of Nassau
United States Court of Appeals for the Second Circuit
819 F.3d 581 (2016)
Garden City had no affordable housing and a relatively low minority population. Nassau County (defendant) put two properties in Garden City up for sale. Nassau County proposed to zone the properties as multi-family residential group (R-M). Many Garden City residents objected, citing concerns about increased traffic, their desire to retain the “character” of single-family housing, and the consequences of introducing affordable housing. In response, Garden City proposed and quickly adopted a new, residential-townhouse (R-T) zoning category. Nassau County solicited proposals to purchase the properties, including a minimum bid. MHANY Management, Inc. (MHANY) (plaintiff) concluded that, given the minimum bid, it would be financially impossible to build affordable housing on R-T land. After the land was sold to another company, MHANY prepared four proposals outlining what it could have provided under the original R-M zoning. Each proposal contained at least 15 percent affordable housing. MHANY brought suit, alleging that Nassau County’s change to R-T zoning violated the Fair Housing Act (FHA), because it effectuated disparate treatment and disparately impacted minorities. At trial, MHANY presented expert testimony that under its four proposals, the likely renter pool would have been 18 to 32 percent minority. Under the accepted R-T zoning bid, the expert predicted that only three to six minority households could afford to purchase a single-family home. Nassau County claimed the zoning decision was made to prevent increased traffic and overcrowded schools. The district court found for MHANY. Nassau County appealed.
Rule of Law
Holding and Reasoning (Pooler, J.)
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