Cuyahoga Falls v. Buckeye Community Hope

Summary

        U.S. Supreme Court

        The Sixth Circuit held a city's enforcement of a referendum which was motivated by racial bias is a violation of equal protection.

        In 1996, Buckeye Community Hope Foundation, a non-profit organization, sought to build an affordable housing project in the City of Cuyahoga Falls. Due to the project's size, three public meetings were held. The meetings indicated the citizens' mixed support. The housing project was approved in the form of Ordinance 48-1996. Over 4,300 citizens filed a facially neutral referendum petition to seek a popular vote on the Ordinance. The City then stayed the Ordinance until the referendum was resolved. Buckeye filed suit in state court contending the referendum violated the Ohio constitution. The court upheld the referendum and denied Buckeye's request for injunctive relief. The Ordinance was defeated in the referendum election. The Ohio Supreme Court reversed and the project has since been completed. Buckeye filed an action in federal court seeking damages for civil rights violations. Buckeye argued the City violated equal protection and due process clauses of the Constitution and the Fair Housing Act. The City was awarded summary judgment. Buckeye appealed. The Sixth Circuit reversed.

        Certiorari granted. The Sixth Circuit held the City committed equal protection and due process violations when the City Council gave force to the racial bias of their citizens by permitting the referendum to stay the effectiveness of Ordinance 48-1966. In this matter, the Circuit court found a jury could reasonably find the opposition was racially motivated. "[A] governmental body may not escape liability under the Equal Protection Clause merely because its discriminatory action was undertaken in response to the desires of a majority of its citizens." United States v. Yonkers Board of Education, 837 F. 2d 1131 (2d Cir. 1987).

— Brian Cardile