United States v. City of Black Jack, Missouri
United States Court of Appeals for the Eighth Circuit
508 F.2d 1179 (1974)
The City of Black Jack, Missouri (defendant), a St. Louis suburb that was roughly 1-2% Black, incorporated in 1970 and quickly passed an ordinance banning further multifamily housing construction, shortly after a nonprofit sought land there to relocate low-income residents from St. Louis's mostly Black inner-city neighborhoods. At the time, about 40% of Black St. Louis County residents lived in overcrowded housing compared to 14% of white residents, against a backdrop of historical, racially motivated housing discrimination in the area. The United States (plaintiff) sued, alleging the ordinance violated the Fair Housing Act; the city defended the ordinance as serving traffic control, school-classroom size, and neighboring property values, and the district court ruled in the city's favor, finding no discriminatory effect. The government appealed.
Whether a plaintiff establishes a prima facie case of racial discrimination under the Fair Housing Act by showing that the defendant's conduct actually or predictably results in racial discrimination, without proving discriminatory intent.