Village of Arlington Heights v. Metropolitan Housing Development Corp.

Status

4,496 later cases cite Village of Arlington Heights v. Metropolitan Housing Development Corp.; 84 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Treatments

Limited

• The Supreme Court of South Carolina declined to extend Arlington Heights's dual-motivation doctrine to Batson challenges, holding that any discriminatory reason for a peremptory strike taints the entire jury-selection process even when nondiscriminatory reasons were also given.

  Payton v. Kearse · Supreme Court of South Carolina · filed January 12, 1998

  Some courts follow an approach taken in other areas of Equal Protection jurisprudence ... and have adopted the dual motivation doctrine. ... Although the United States Supreme Court has not yet addressed this doctrine’s applicability to a Batson challenge, other courts have followed Howard in adopting the dual motivation doctrine in the Batson context. ... In our opinion, it is inappropriate to apply the dual motivation doctrine in the Batson context. Once a discriminatory reason has been uncovered — either inherent or pretextual — this reason taints the entire jury selection procedure. ... This doctrine has been adopted by the United States Supreme Court in other areas of Equal Protection analysis. See Hunter v. Underwood, 471 U.S. 222, 105 S.Ct. 1916, 85 L.Ed.2d 222 (1985); Village of Arlington Heights v. Metropolitan Housing Development Corp., 429 U.S. 252, 97 S.Ct. 555, 50 L.Ed.2d 450 (1977).

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• The Sixth Circuit confined Arlington Heights's statement that a corporation has no racial identity to the Fourteenth Amendment standing context, holding that the statement was noncontrolling dicta and did not bar corporations from asserting statutory race-discrimination claims under 42 U.S.C. § 1981.

  Inner City Contracting, LLC v. Charter Township of Northville · Sixth Circuit · filed November 30, 2023

  F&V argues that dicta in the Supreme Court’s decision in Vill. of Arlington Heights v. Metro. Hous. Dev. Corp. prohibits corporations from alleging racial discrimination. In that case, the Supreme Court stated, “[a]s a corporation, [the plaintiff] has no racial identity and cannot be the direct target of the petitioners’ alleged discrimination.” 429 U.S. 252, 263 (1977). This line does not control this case for two reasons. First, the Court in Arlington Heights did not address statutory standing; its opinion concerned an alleged violation of the Fourteenth Amendment. Second, the Court found that another plaintiff had standing to assert the claims at issue, rendering ... the language unpersuasive dicta irrelevant to the Court’s ultimate holding. ... F&V’s argument that Supreme Court dicta controls must fail, and we are left with persuasive precedent from sister Circuits that corporations have standing to allege violations of § 1981.

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