Arlington Heights v. Metropolitan Housing Corp

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Arlington Heights v. Metropolitan Housing Corp., 429 U.S. 252 (1977), was a case decided by the United States Supreme Court in which the village of Arlington Heights, Illinois refused to rezone property so that low-income housing could be built. The developers seeking zoning changes sued, saying that the decision not to rezone violated the equal protection clause of the Fourteenth Amendment to the Constitution. The theory of the case was one of discriminatory impact. The plaintiffs relied on Yick Wo and Gomillion v. Lightfoot, in which plaintiffs succeeded in challenging laws that were written in racially neutral terms, but that severely detrimented one racial group. The court has never recognized racial impact as an adequate basis for a constitutional violation all by itself, but has always required that the plaintiffs prove a discriminatory intent. However, in Yick Wo and Gomillion, the court accepted an extremely disproportionate impact as evidence proving a discriminatory intent. The plaintiffs in this case asserted that the disparate racial impact of the zoning proved that the city intended to discriminate against racial minorities.

The SCOTUS dealt with two significant issues: First, whether the plaintiffs had standing. Second, whether the zoning was in violation of equal protection.

Regarding the second issue, the court stated that in order to use disparate impact alone to prove discrimination, they plaintiffs must show a "clear pattern, unexplainable on grounds other than race." Ultimately the court ruled against the plaintiffs. This case reaffirmed the principle articulated in Washington v. Davis, that discriminatory impact was not a per se violation of equal protection, but merely evidence of discriminatory intent. While appearing to allow considerable latitude for the use of statistical evidence of discrimination, in application Arlington Heights and similar cases almost entirely foreclose using discriminatory impact to prove intent. Ironically, many of the most fervent opponents of the use of statistics to prove racial discrimination end up using those statistics themselves to support overturning affirmative action. See Grutter, Rehnquist J dissenting.