United States v. Charlottesville Redevelopment & Housing Authority

718 F. Supp. 461, 1989 U.S. Dist. LEXIS 8569, 1989 WL 81782
CourtDistrict Court, W.D. Virginia
DecidedJuly 24, 1989
DocketCiv. A. 86-0033-C
StatusPublished
Cited by7 cases

This text of 718 F. Supp. 461 (United States v. Charlottesville Redevelopment & Housing Authority) is published on Counsel Stack Legal Research, covering District Court, W.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Charlottesville Redevelopment & Housing Authority, 718 F. Supp. 461, 1989 U.S. Dist. LEXIS 8569, 1989 WL 81782 (W.D. Va. 1989).

Opinion

MEMORANDUM OPINION

MICHAEL, District Judge.

This action was brought by the United States to challenge the allegedly race-conscious, preferential plan employed by defendant Charlottesville Redevelopment and Housing Authority (“CRHA”) to assign tenants to its public housing facilities from its waiting list. Both sides seek summary judgment, the United States asking for judgment which would strike down CRHA’s plan and CRHA asking that this court declare their preferential plan to be acceptable legally. For the reasons elaborated below, this court finds that CRHA’s tenant assignment plan violates 42 U.S.C. § 3604(a), (b), and (c) and, therefore, grants the motion for summary judgment of the United States.

I.

For twenty-five years, defendant CRHA has operated public housing projects in Charlottesville, Virginia. Arrington Affidavit, ¶1 25. From 1964 until 1980, CRHA operated only one public housing project, the Westhaven Project, and the residential units of this project were rented by blacks only, except for a period of several months in the 1970s. Id. at 1128. In 1980, CRHA developed a new tenant selection policy which gave preferential treatment to white applicants for public housing in Charlottes-ville and which aimed, on its own terms, to achieve a 50/50 mix of black and white residents in its public housing. Id. at ¶ 31. As a result of this policy, black applicants for spaces in the public housing projects administered by CRHA have had to wait considerably longer than white applicants. 1 The disparity in waiting time is not disputed by defendant CRHA. Memorandum in Support of Defendant’s Motion for Summary Judgment at 2. This matter is ripe for summary judgment because the material facts surrounding the public housing administered by CRHA and the contours of its preferential selection process are not in dispute. Rule 56, Fed.R.Civ.P.

II.

The United States alleges that CRHA violates a number of sections of the Fair Housing Act through its policy which gives certain preferences to white applicants for rental units. Specifically, plaintiff alleges that the tenant assignment policy of CRHA violates 42 U.S.C. § 3604, subsections (a) through (d). 2 In particular, *463 plaintiff alleges that the policy instituted by CRHA and the administrative actions spawned by that policy (1) “make unavailable or deny ... dwelling[s] to [blacks] because of race ..(2) “discriminate against [blacks] in the terms, conditions, or privileges of ... rental of ... dwellingfs] ... because of race ...,” (3) constitute statements with respect to the rental of housing units which indicate a “preference, limitation or discrimination” which is based on race, and (4) constitute representations to blacks that “because of race” “that ... [a] dwelling is not available for inspection, sale, or rental when such dwelling is in fact so available.” 3

Plaintiff has not offered evidence of any individual black applicant or would-be tenant of CRHA public housing who can testify that he or she did not receive any public housing at all because of their race. However, plaintiff need not offer this sort of proof in order to prevail in its claim. It is not necessary for the court to find that blacks have been turned away from public housing by CRHA, that they have been told not to apply for public housing, or that they have been told that they would not be eligible for apartments at all. Rather, for the purposes of assessing whether there has been a violation of 42 U.S.C. § 3604(a)-(c), being made to wait longer because of race than is justified for public housing is functionally equivalent to being denied public housing. 4

The court finds, after examining the contours of the tenant assignment plan of CRHA and the allegations offered by plaintiff, that the circumstances of this case are such that this court is properly guided by persuasive precedent. United States v. Starrett City Assoc., 840 F.2d 1096 (2d Cir.), cert. den., — U.S. —, 109 S.Ct. 376, 102 L.Ed.2d 365 (1988). In examining a pattern of preferential assignment of white applicants to a low income housing complex which was privately owned, the Second Circuit found that, despite the con-cededly beneficial intention of the preferential plan, its effects were legally impermissible. “Housing practices unlawful under Title XIII include not only those motivated by a racially discriminatory purpose, but also those that disproportionally affect minorities.” Id. at 1100. Motivation alone will not serve to save an otherwise constitutionally or legally infirm plan. Furthermore, the fact that the housing complex in Starrett City was privately owned did not serve to put it beyond the purview of the Title XIII challenges brought by the United States. Id. at 1100-1101. As does CRHA infra, the appellant in Starrett City raised the defense of the “tipping phenomenon”: the prospect that “white flight” will affect *464 the complex and, in the case of the Star-rett City the entire neighborhood, leaving the complex effectively or virtually segregated. The Second Circuit also distinguished between programs which elicit minority participation and those which limit the access of minorities or disadvantaged groups. 5 Finally, the Second Circuit held that such a preferential treatment is not permissible when the program in question is not temporary and has not been enacted to remedy specific past discrimination. Id. at 1102-03.

III.

Since this court has before it cross motions for summary judgment, the arguments advanced and the defenses offered in response to those arguments are largely mirror images of each other. Therefore, the court will turn to the defenses offered by CRHA as a rebuttal to plaintiff’s motion for summary judgment and as support of CRHA’s own motion for summary judgment.

A.

CRHA argues that since the Richmond Area Office of Housing and Urban Development (“HUD”) commended CRHA’s attempt to integrate its housing units, this approval by HUD serves to es-top the United States from pursuing this action. Memorandum in Support of Defendant’s Motion for Summary Judgment at 4-5. HUD not only “commended” CRHA in 1981 for these efforts but reviewed its plan in 1983 and suggested additional ways to make the efforts at integration more effective. Id. at 5. There are three reasons why this proffered defense is not sufficient to turn away plaintiff’s allegations. First, a mere letter of approval from a HUD field office could hardly be considered sufficient to estop the United States.

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718 F. Supp. 461, 1989 U.S. Dist. LEXIS 8569, 1989 WL 81782, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-charlottesville-redevelopment-housing-authority-vawd-1989.