finding that tenants had alleged sufficient injury and thus had standing to sue under the Civil Rights Act of 1968 where they alleged that Defendant’s discriminatory practice of not renting to blacks had injured them in that “(1) they had lost the social benefits of living in an integrated community; (2) they had missed business and professional advantages which would have accrued if they had lived with members of minority groups; (3) they had suffered embarrassment and economic damage in social, business, and professional activities from being ‘stigmatized’ as residents of a ‘white ghetto.’”
How later courts described this case
- finding that tenants had alleged sufficient injury and thus had standing to sue under the Civil Rights Act of 1968 where they alleged that Defendant’s discriminatory practice of not renting to blacks had injured them in that “(1) they had lost the social benefits of living in an integrated community; (2) they had missed business and professional advantages which would have accrued if they had lived with members of minority groups; (3) they had suffered embarrassment and economic damage in social, business, and professional activities from being ‘stigmatized’ as residents of a ‘white ghetto.’”
- explaining that because Congress intended to define standing under the Civil Rights Act of 1964 as broadly as possible under Article III, the Fair Housing Act conferred standing to sue on any resident of the housing unit who had been injured by racial discrimination in the management of the facilities
- finding, in an action by tenants challenging allegedly racially discriminatory practices of landlords that the definition of “‘persons aggrieved’ in the Civil Rights Act of 1968 is consistent with Congress’s intent to “define sanding as broadly as is permitted by Article III of the Constitution.”
- holding that the term “aggrieved person” in § 810(a) of the Fair Housing Act, which the Act defined to include “[a]ny person who claims to have been injured by a discriminatory housing practice,” demonstrated Congressional intent to confer standing to the fullest extent permitted by Article III
Written by the judges who cited it.
Later courts went against this
Reported overruled by Thompson v. North American Stainless, LP, 178 L. Ed. 2d 694 (2011) — not on the Supreme Court's list
Moreover, Trafficante was subsequently overturned by Thompson v. North American Stainless, LP, 562 U.S. 170, 131 S.Ct. 863, 178 L.Ed.2d 694 (2011), which held that only parties whose rights under the FHA have been aggrieved may bring suit, not others who were tangentially injured by the violation.
Distinguished
Distinguished by Gladstone, Realtors v. Village of Bellwood, 441 U.S. 91 (1979)
Petitioners argue that Trafficante is distinguishable because the complainants in that case alleged harm to the racial character of their “community,” whereas respondents refer only to their “society.
The opinion
Mr. Justice White,
with whom Mr. Justice Black-mun and Mr. Justice Powell join,
concurring.
Absent the Civil Rights Act of 1968,1 would have great difficulty in concluding that petitioners’ complaint in this case presented a case or controversy within the jurisdiction of the District Court under Art. Ill of the Constitution. But with that statute purporting to give all those who are authorized to complain to the agency the right also to sue in court, I would sustain the statute insofar as it extends standing to those in the position of the petitioners in this case. Cf. Katzenbach v. Morgan, 384 U. S. 641, 648-649 (1966); Oregon v. Mitchell, 400 U. S. 112, 240, 248-249 (1970). Consequently, I join the Court’s opinion and judgment.