On October 19, 2015, ten years after the case was first filed, the Second Circuit upheld a federal jury’s finding that zoning policies used by the City Saratoga Springs had a discriminatory disparate impact on African Americans and families with children. Relman Colfax filed this Fair Housing Act action on behalf of The Anderson Group, an Albany, New York builder, after Saratoga Springs prevented The Anderson Group from building a mixed-income housing development in the virtually all-white city of Saratoga Springs. The evidence introduced in the case showed that the City blocked the Anderson’s proposed development, Spring Run Village, as part of a continuing discriminatory policy that excluded and segregated African Americans by manipulating its zoning and land use rules to ensure that all affordable housing is contained in a small downtown area.
When the Anderson family sought to build Spring Run Village, a development with fifty to sixty affordable units, on property they own outside the downtown area, the City rejected the Anderson's application and rezoned the site from a classification where high-density residential and commercial uses were “preferred” and “encouraged” to a classification where such a development was prohibited.
The rezoning prevented Spring Run Village and had the effect of preventing the construction of any affordable housing on the property. The City took these actions despite an acknowledged affordable housing crisis in the City. That crisis is disproportionately borne by African Americans and families with children in the area who face extreme housing costs burdens.
In its opinion, the Second Circuit upheld The Anderson Group’s standing to bring suit under the Fair Housing Act, reversed the district court’s finding of an inconsistent verdict, and reinstated the jury’s finding of liability against Saratoga Springs on The Anderson Group’s disparate impact claim under the Fair Housing Act.
Case Citation
The Anderson Group, LLC v. City of Saratoga Springs, No. 05-CV-1369 GLS (N.D.N.Y.)