Gallagher v. Magner Ex Rel. City of St. Paul's Department of Neighborhood Housing & Property Improvement, 619 F.3d 823 (2010)

Citation: Gallagher v. Magner Ex Rel. City of St. Paul's Department of Neighborhood Housing & Property Improvement, 619 F.3d 823 (2010)
Parent Document: Gallagher v. Magner Ex Rel. City of St. Paul's Department of Neighborhood Housing & Property Improvement, 619 F.3d 823 (2010)
Jurisdiction: United States (federal)
Effective Date: 2010-09-01
Original Source: https://www.courtlistener.com/opinion/174536/gallagher-v-magner-ex-rel-city-o... ↗

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Appellants also argue that discriminatory intent should be inferred from the
City’s knowledge that its actions would likely have a disproportionate impact on racial
minorities. The Supreme Court discussed a similar theory in Village of Arlington
Heights v. Metropolitan Development Corp., 429 U.S. 252 (1977). There, the court
of appeals held that a city’s zoning decision violated the equal protection clause of the
Fourteenth Amendment, which required a finding of discriminatory intent, solely
because the “ultimate effect” of the decision was racially discriminatory. Id. at 254.
The Supreme Court explained that in some cases, “an important starting point” for
determining discriminatory intent is whether an official action “bears more heavily
on one race than another.” Id. at 266 (quotation omitted). “Sometimes a clear pattern,
unexplainable on grounds other than race, emerges from the effect of the state action
even when the governing legislation appears neutral on its face.” Id. The Court
explained that discriminatory impact alone is not determinative outside of “rare” cases
where the pattern of discriminatory effect is “stark.” Id. Ultimately, the Court held
that an arguable disparate impact on racial minorities was insufficient to prove a
discriminatory purpose. Id. at 269–71.

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