Case: Huntington Branch NAACP v. Town of Huntington

Plaintiffs, a class action comprised of the NAACP, minority citizens and minority citizens, community organizations in Huntington, New York filed suit against the Town of Huntington and the Department of Housing and Urban Development (HUD) over Defendants' opposition to a low-income multi-family housing development. Plaintiffs sued in the U.S. District Court for the Eastern District of New York, alleging violations of the Fair Housing Act, 42 U.S.C. 3601-3619, federal civil rights statutes, 42 U.S.C. 1981, 1982, and 1983, and state law. Plaintiffs alleged that the Defendants' opposition to the proposed development was based on racial considerations.

U.S. District Court Judge Costantino dismissed the Plaintiffs' complaint in its entirety on January 18, 1981, holding that a court-ordered change in the Defendants' zoning laws would not remedy Plaintiffs' injury because there were insufficient Section 8 funds to build the proposed housing structure. Huntington Branch NAACP v. Huntington, 530 F. Supp. 838 (E.D.N.Y. 1981). On September 28, 1982, the Second Circuit reversed the District Court's dismissal, holding that the uncertainty of federal of funds in the future did not render the Plaintiff's injury non-redressable. Huntington Branch, NAACP v. Huntington, 689 F.2d 391 (2d Cir. 1982).

On remand from the appellate court, District Court Judge Glasser certified a class action against the Town of Huntington on November 7, 1983; the Plaintiffs dropped their claims against the federal agency. The District Court denied a defense motion for summary judgment on May 13, 1984. On September 24, 1987, Judge Glasser ruled in favor of the Defendant-town on all of Plaintiff's claims in the case, finding that there was insufficient evidence of purposeful discrimination and that the Defendant had provided sufficient non-discriminatory, non-pre-textual explanations for its actions.

On appeal, the Second Circuit again reversed the District Court, this time finding that Plaintiffs had demonstrated a violation of the Fair Housing Act based on Defendant's purposeful use of zoning laws to impede minority home ownership in the town. Huntington Branch, NAACP v. Huntington, 844 F.2d 926 (2d Cir. 1988). The Second Circuit ordered the City to implement changes to its zoning laws to accommodate the proposed development.

The Supreme Court affirmed the Second Circuit's ruling on November 7, 1988, in a per curiam opinion delivered without oral argument. Huntington v. Huntington Branch, NAACP, 488 U.S. 15 (1988).