Term: 2002
Docket: 01-1269
City Of Cuyahoga Falls, Ohio, Et Al. v. Buckeye Community Hope Foundation Et Al.
- Pro
01-1269 CUYAHOGA FALLS v. BUCKEYE COMMUNITY HOPE FOUNDATION Ruling below: CA 6, 263 F.3d 627 QUESTIONS PRESENTED FOR REVIEW 1. In considering a claim against a municipal corporation for intentional discrimination arising out of a facially neutral and judicially upheld referendum petition, may the court inquire into the motivations of a handful of the citizens who expressed support for the referendum and impute those motivations to the entire municipal corporation? 2. In light of the constitutional freedom of political expression, can a disparate impact claim under the Fair Housing Act be maintained against a municipal corporation for the alleged impact of the filing of a facially neutral and judicially upheld referendum petition? 3. Does the due process clause of the constitution require a municipal corporation to issue building permits when the underlying conditions for the issuance of building permits have not been met and the municipal corporation's withholding of the permits is required by the judgments of state courts of competent jurisdiction? 4. Does 28 U .S.C. 1738 require a Federal District Court to apply res judicata to dismiss a federal case arising out of the same factual transaction as an earlier case decided by Ohio state courts? CERT. GRANTED: 6/24/02 Limited to questions 1, 2 and 3 presented by the petition.
In the case of City of Cuyahoga Falls, Ohio v. Buckeye Community Hope Foundation (2002), the U.S. Supreme Court ruled in favor of Buckeye Community Hope Foundation, a non-profit organization that aimed to build low-income housing in Cuyahoga Falls, Ohio. The city had attempted to block construction through a referendum process after approving necessary permits for the project. The foundation argued this was racially motivated and violated both their equal protection rights under the Fourteenth Amendment and their right to due process. In its decision, the court held that referenda are part of legislative processes and thus immune from such challenges unless there is clear evidence they were used as tools for discrimination or caused an undue delay on property interests without due process.
In the dissenting opinion for City of Cuyahoga Falls, Ohio v. Buckeye Community Hope Foundation et al., Justice Stevens argued that the majority's decision failed to recognize the potential discriminatory intent behind a city-wide referendum on a low-income housing project. He believed that there was sufficient evidence to suggest racial animus may have motivated this action and thus it should be subject to strict scrutiny under equal protection principles. The fact that citizens were allowed to vote on whether or not they wanted low-income housing in their community could potentially allow discrimination against those who would live in such housing, many of whom are likely members of minority groups. Additionally, he disagreed with the majority's assertion that any delay caused by such referendums is insignificant; instead, he contended these delays can cause significant harm by preventing needed affordable housing from being built promptly.
