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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These premises, together, reasonably demonstrate that the City’s aggressive
enforcement of the Housing Code resulted in a disproportionate adverse effect on
racial minorities, particularly African-Americans. Viewed in the light most favorable
to Appellants, the evidence shows that the City’s Housing Code enforcement
temporarily, if not permanently, burdened Appellants’ rental businesses, which
indirectly burdened their tenants. Given the existing shortage of affordable housing
in the City, it is reasonable to infer that the overall amount of affordable housing
decreased as a result. And taking into account the demographic evidence in the
record, it is reasonable to infer racial minorities, particularly African-Americans, were
disproportionately affected by these events. See 215 Alliance v. Cuomo, 61 F. Supp.
2d 879, 889 (D. Minn. 1999) (“[M]inority, elderly, and disabled tenants face
significant hurdles in locating housing above and beyond the mere shortage of
low-income housing. . . . Any policy which results in the displacement of low-income
tenants will disproportionately affect these particular low-income citizens whose
housing options are especially constrained.”). Though there is not a single document
that connects the dots of Appellants’ disparate impact claim, it is enough that each
analytic step is reasonable and supported by evidence.

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