Trafficante v. Metropolitan Life Insurance Co.

Supreme Court of the United States · 1972 · Federal Courts

Federal CourtsStandingFair Housing Actstandingperson aggrievedFair Housing Act42 U.S.C. § 3610discriminatory housing practice

Facts

Two existing tenants at Parkmerced, one black and one white, alleged that the apartment complex owner discriminated against nonwhite applicants in renting apartments. They claimed the owner discouraged nonwhite applicants, manipulated waiting lists, delayed applications, and used discriminatory acceptance standards. The tenants alleged they were injured because they lost the social and other benefits of living in an integrated community and were stigmatized as residents of a "white ghetto." After HUD proceedings did not produce voluntary compliance, they brought suit under the Civil Rights Act of 1968.

Issue

Whether existing tenants of a housing complex, who were not themselves denied housing, qualify as "persons aggrieved" under § 810(a) of the Civil Rights Act of 1968 and therefore may sue based on injuries allegedly caused by racial discrimination against nonwhite applicants in the same complex.

Rule

Under § 810(a) of the Civil Rights Act of 1968, the term "person aggrieved" is to be given a generous construction, extending standing to all persons in the same housing unit who allege injury in fact from racial discrimination in the management of those facilities, so long as the standing asserted is as broad as Article III permits.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Jamal Ortiz has lived for three years in the Harbor View Towers complex in Seattle. He files a HUD complaint alleging that Harbor View Residential, LLC routinely discourages Latino and Black applicants from renting there, and he alleges that as a current tenant he has lost the social and professional benefits of living in an integrated residential community.

If Jamal sues in federal district court after HUD fails to secure voluntary compliance within the statutory period, what is the strongest argument that he has standing under the Act?

Explanation. The majority construed the Act's phrase "any person who claims to have been injured by a discriminatory housing practice" generously, as broadly as Article III permits, at least for tenants in the same housing unit. A current tenant who alleges loss of the benefits of interracial association from discrimination in the management of that very complex alleges injury in fact sufficient at the pleading stage. The Court rejected the idea that only the direct object of discrimination may sue, and private suits do not depend on Attorney General participation.