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Law School Case Brief

Hills v. Gautreaux - 425 U.S. 284, 96 S. Ct. 1538 (1976)


In the event of a constitutional violation all reasonable methods be available to formulate an effective remedy, and every effort should be made by a federal court to employ those methods to achieve the greatest possible degree of relief, taking into account the practicalities of the situation. Once a right and a violation have been shown, the scope of a district court's equitable powers to remedy past wrongs is broad, for breadth and flexibility are inherent in equitable remedies.


After the United States District Court for the Northern District of Illinois, in a class action against defendant Chicago Housing Authority (CHA) by plaintiffs-respondents African-American tenants in or applicants for public housing in Chicago, had found that the Authority had violated the plaintiffs' constitutional rights by selecting public housing sites and assigning tenants on the basis of race, the District Court dismissed the plaintiffs' complaint in their companion suit against the United States Department of Housing and Urban Development (HUD) based on the Department's alleged participation in the discriminatory housing program. The United States Court of Appeals for the Seventh Circuit reversed and ordered the District Court to enter summary judgment for the plaintiffs, holding that the Department had violated both the Fifth Amendment and 601 of the Civil Rights Act of 1964 by knowingly assisting the Authority's racially discriminatory public housing program through providing financial assistance and other support for such program. On remand, the District Court consolidated the two cases and after denying the plaintiffs' motion to consider metropolitan area relief, ordered relief within the city limits only. The Court of Appeals reversed and remanded the case for further consideration of the issue of metropolitan area relief. The plaintiffs appealed the decision.


In the case at bar, was a metropolitan area remedy impermissible as a matter of law?




The Supreme Court of the United States held that a metropolitan area remedy in this case was not impermissible as a matter of law. According to the Court, a judicial order directing relief beyond Chicago's boundary lines did not necessarily entail coercion of uninvolved governmental units, for petitioner and CHA had authority to operate outside Chicago city limits. The Court affirmed the judgment of the court of appeals that remanded the case for additional evidence, but changed the consideration required for the issue of metropolitan relief. The Court concluded that a metropolitan area remedy was not impermissible as a matter of law. A remedial plan designed to insure that HUD will utilize its funding and administrative powers in a manner consistent with affording relief to the respondents-plaintiffs tenants need not abrogate the role of local governmental units in the federal housing-assistance programs.

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