Village of Arlington Heights v. Metropolitan Housing Development Corp., 429 U.S. 252 (1977)

Author: Powell (majority) Outcome: Village wins ($d = 0$: no EP violation found) Concurrences: Marshall (in part) Dissents: White

1. Holding ($H_t$)

"Proof of a racially discriminatory intent or purpose is required to show a violation of the Equal Protection Clause of the Fourteenth Amendment, and respondents failed to carry their burden of proving that such an intent or purpose was a motivating factor in the Village's rezoning decision." (p. 264-271)

As constraint on admissible $(w, c)$: The holding establishes that a racially disproportionate impact alone does not suffice to prove an Equal Protection violation; there must be evidence of discriminatory intent. This constrains future decision rules to require proof of intent when assessing EP claims involving facially neutral policies with disparate impacts.

What the holding does NOT constrain:

The specific evidentiary threshold for proving discriminatory intent
The applicability of this intent requirement to other areas of law beyond zoning and housing
How to weigh evidence of intent against other factors in a mixed-motive case
The potential relevance of disparate impact under statutory claims, such as the Fair Housing Act

2. Fact vector $z_t$

2a. Raw salient facts

Rezoning denial: The Village denied rezoning from single-family to multiple-family classification for a proposed low- and moderate-income housing project (p. 253). Favors: government.
Racial impact: The denial disproportionately affected blacks, as they constituted 40% of those eligible for the housing, despite being a smaller percentage of the overall population (p. 259). Favors: plaintiff.
Historical zoning consistency: The area had been zoned single-family since 1959, and the Village had a policy of using R-5 zoning as a buffer between single-family and incompatible uses (p. 269). Favors: government.
Community opposition: Public meetings revealed vocal opposition to the project, with some comments addressing the racial integration aspect (p. 256). Favors: plaintiff.
Procedural regularity: The rezoning request followed normal procedures, and the Village's buffer policy had been consistently applied (p. 269). Favors: government.
Economic injury to MHDC: MHDC incurred expenses related to the rezoning application, which would be lost if the rezoning was not granted (p. 262). Favors: plaintiff.

2b. Dimension mapping

Dimension	Value	Raw fact(s) mapped	Textual basis
D1 Facial classification	Low	Rezoning denial	The policy is facially neutral; no explicit racial classification (p. 264)
D2 Protected trait	Race	Racial impact	Disproportionate impact on blacks (p. 259)
D3 Intent evidence	Low	Historical zoning consistency, procedural regularity	No evidence of discriminatory intent found (p. 269)
D4 Interest strength	Moderate	Zoning policy, property values	Protecting property values and zoning integrity (p. 259)
D5 Means-ends fit	Tight	Buffer policy consistency	Consistent application of zoning policy (p. 269)
D6 Stigma / caste	Low	Community opposition	Opposition partly based on racial integration (p. 256)
D7 Institutional setting	Zoning	Rezoning denial	Zoning decision context (p. 253)
D8 Precedent density	High	Washington v. Davis	Reinforces intent requirement for EP claims (p. 265)

Unmapped facts:

Economic injury to MHDC does not map directly to any EP dimension but highlights the financial stakes for plaintiffs in zoning disputes.

Notable: The Court emphasizes the need for discriminatory intent, not just impact, to establish an EP violation, reinforcing the precedent set in Washington v. Davis.

3. Treatment of prior holdings ($\mathcal{F}_t$ update)

Washington v. Davis (1976)

Status: Relied on. The Court reaffirms that discriminatory intent is required for an EP violation (p. 265).
Characterization: The Court cites Davis to support the principle that disproportionate impact alone is insufficient for an EP claim.
Model interpretation: Reinforces the constraint that intent must be shown, narrowing $\mathcal{F}_t$ by excluding rules based solely on impact.

Keyes v. School Dist. No. 1 (1973)

Status: Relied on. Cited for the principle that intent is necessary in school desegregation cases (p. 265).
Characterization: Used to illustrate the broader application of the intent requirement across contexts.
Model interpretation: Supports the generalization of the intent requirement beyond the specific facts of zoning.

Yick Wo v. Hopkins (1886)

Status: Distinguished. Cited as an example of a clear pattern of discrimination (p. 266).
Characterization: The Court contrasts Yick Wo's stark pattern with the lack of such evidence in Arlington Heights.
Model interpretation: Clarifies that stark, unexplainable patterns can substitute for direct evidence of intent, but such cases are rare.

4. Overruling (constraint removal at cost $C$)

No overruling in this case. The Court explicitly relies on existing precedent, particularly Washington v. Davis, to affirm the requirement of discriminatory intent for EP claims. There is no indication of removing or altering any established constraints.

5. Breadth

Narrow reading (what the Court explicitly holds):

A racially disproportionate impact alone does not establish an EP violation; proof of discriminatory intent is required.
Applies specifically to zoning decisions and similar contexts where facially neutral policies are challenged.

Broad reading (what the reasoning supports):

The intent requirement could extend to other areas of law where facially neutral policies have disparate impacts, reinforcing the need for intent evidence in EP claims.
Could influence how courts assess intent in mixed-motive cases, potentially affecting a wide range of civil rights litigation.

Breadth ambiguity:

The decision leaves open how much evidence is needed to prove intent and how courts should weigh mixed motives.
The applicability of this standard to statutory claims under laws like the Fair Housing Act remains unresolved.

6. Concurrences / dissents (alternative admissible theories)

Marshall, J., concurring in part and dissenting in part (joined by Brennan, J.)

Alternative constraint structure: Marshall agrees with the majority on standing but would remand the entire case to the Court of Appeals for reconsideration in light of Washington v. Davis.
Key disagreement: Emphasizes the need for further proceedings to assess the evidence under the clarified intent standard, suggesting a more thorough examination than the majority undertakes.

White, J., dissenting

Alternative constraint structure: White argues for remanding the case to the Court of Appeals, criticizing the majority for not following the usual practice of remanding after an intervening decision.
Key disagreement: Disagrees with the majority's decision to resolve the case without allowing the lower court to apply the new standard from Washington v. Davis.

7. Reasoning revealing implicit weights on dimensions

Intent requirement emphasized (D3 weight is high):

"Proof of racially discriminatory intent or purpose is required to show a violation of the Equal Protection Clause." (p. 265)

The Court places significant weight on the need for intent evidence, indicating that mere impact is insufficient for EP claims.

Procedural regularity (D5 weight is high):

"The rezoning request progressed according to the usual procedures." (p. 269)

The Court highlights the importance of procedural consistency, suggesting that deviations might indicate improper motives.

Historical consistency (D5 weight is high):

"The area around the Viatorian property has been zoned R-3 since 1959." (p. 269)

Emphasizes the relevance of historical zoning practices in assessing intent, reinforcing the importance of consistent application over time.

Impact vs. intent (D8 weight is high):

"Disproportionate impact is not irrelevant, but it is not the sole touchstone of an invidious racial discrimination." (p. 265)

The Court clarifies the limited role of impact evidence, reinforcing the intent requirement as a critical threshold for EP claims.