Fair Housing Act – Statutory Interpretation

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US Supreme Court

Case Name: Bank of America Corp, et al v. City of Miami, Florida

Case No.: 15-1111

Focus: Fair Housing Act –  Statutory Interpretation

The City is an “aggrieved person” authorized to bring suit under the FHA.

“In addition to satisfying constitutional standing requirements, see Spokeo, Inc. v. Robins, 578 U. S. ___, ___, a plaintiff must show that the statute grants the plaintiff the cause of action he or she asserts. It is presumed that a statute ordinarily provides a cause of action “only to plaintiffs whose interests ‘fall within the zone of interests protected by the law invoked.’ ” Lexmark Int’l, Inc. v. Static Control Components, Inc., 572 U. S. ___, ___. The City’s claims of financial injury are, at the least, “arguably within the zone of interests” the FHA protects. Association of Data Processing Service Organizations, Inc. v. Camp, 397 U. S. 150, 153. The FHA defines an “aggrieved person” as “any person who” either “claims to have been injured by a discriminatory housing practice” or believes that such an injury “is about to occur,” 8 U. S. C. §3602(i). This Court has said that the definition of “person aggrieved” in the original version of the FHA “showed ‘a congressional intention to define standing as broadly as is permitted by Article III of the Constitution,’ ” Trafficante v. Metropolitan Life Ins. Co., 409 U. S. 205, 209; and has held that the Act permits suit by parties similarly situated to the City, see, e.g., Gladstone, Realtors v. Village of Bellwood, 441 U. S. 91 (village alleging that it lost tax revenue and had the racial balance of its community undermined by racial-steering practices). Against the backdrop of those decisions, Congress did not materially alter the definition of person “aggrieved” when it reenacted the current version of the Act.”

Vacated and remanded

Concur: Roberts, Ginsburg, Sotomayor, Kagan, Thomas

Dissent: Thomas, Kennedy, Alito

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