United States v. City of Black Jack, Missouri
United States Court of Appeals for the Eighth Circuit
508 F.2d 1179 (1974)
- Written by Sean Carroll, JD
Facts
In 1965, St. Louis County adopted a master plan for an unincorporated area that later became the City of Black Jack (defendant). The plan marked 67 of 1,700 acres for multiple-family housing. In 1969, the Inter Religious Center for Urban Affairs (ICUA) sought land outside the City of St. Louis to relocate low-income individuals living in St. Louis ghettoes. The ICUA chose 11.9 acres of the land that became Black Jack. In 1970, Black Jack was incorporated. Black Jack passed an ordinance prohibiting the construction of any additional multifamily buildings. Black Jack remained mostly undeveloped at that time, containing only 15.2 acres of multifamily housing. The black population in Black Jack was 1 to 2%. Approximately 40% of the black population in St. Louis County, as compared to 14% of the white population, lived in overcrowded situations. The United States government (plaintiff) sued the city, alleging that the ordinance violated the Fair Housing Act. The United States presented evidence of historical, racially motivated housing discrimination in the St. Louis area. Black Jack claimed that the ordinance furthered its governmental interests of traffic control, maintaining appropriate classroom size, and maintaining the property values of neighboring single-family homes. The district court held that the ordinance did not have a discriminatory effect and ruled in favor of the city. The United States appealed.
Rule of Law
Issue
Holding and Reasoning (Heaney, C.J.)
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