United States ex rel. Antidiscrimination Center of Metro New York, Inc. v. Westchester County

Westchester County (defendant) applied to the U.S. Department of Housing and Urban Development (HUD) for certain federal funding, including Community Development Block Grants (CDBG). In order to receive CDBG funds, Westchester County was required to certify that the grant would be administered in accordance with the Civil Rights Act of 1964 and the Fair Housing Act and that Westchester County would affirmatively further fair housing. In order to affirmatively further fair housing, Westchester County was required to conduct an analysis of impediments to fair-housing choices within the county, take steps to overcome the effects of those impediments, and maintain records of its analysis and steps taken. The Anti-Discrimination Center of Metro New York, Inc. (ADC) (plaintiff) filed a lawsuit against Westchester County alleging that it violated the False Claims Act through the certifications it made to HUD when applying for federal funding. The ADC filed a motion for summary judgment and alleged that Westchester County failed to follow the requirements of affirmatively furthering fair housing by focusing exclusively on increasing affordable housing within the county and not taking race into account when analyzing impediments to fair housing. Westchester County argued that it did not have to consider race when analyzing impediments to fair housing, but regardless, that it did consider race and found that race was not a significant barrier to fair-housing choice.