Mt. Holly Gardens Citizens in Action, Inc. v. Township of Mount Holly
Court of Appeals for the Third Circuit · 2011-09-13 · cited 68×
The case involved a challenge by low-income, predominantly minority residents of the Gardens neighborhood in Mount Holly Township, New Jersey, to the Township's redevelopment plan, which called for demolishing their existing affordable homes and replacing them with higher-cost housing. The residents alleged that the plan had a discriminatory disparate impact and reflected intentional discrimination in violation of the Fair Housing Act and other anti-discrimination laws. The district court granted summary judgment to the Township before discovery or an answer. The Third Circuit reversed in part, holding that the district court misapplied the standards for a prima facie disparate-impact claim under the FHA and failed to draw reasonable inferences in the residents' favor, as the record raised genuine factual issues about whether less discriminatory alternatives, such as rehabilitation, were feasible. The court affirmed the dismissal of the intentional-discrimination claim but remanded the case for further proceedings.