Citation: Certiorari to the United States court of appeals for the eleventh circuit
Facts of the Case: This was a suit filed by the Miami City against the Bank of America and Well Fargo Bank based on the allegation of violation of the Fair Housing Act (FHA). One of the main objectives of the FHA is to prohibit racial discrimination about real estate business transactions and allow the aggravated party to file a suit for damages.
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The complainants alleged that both banks intentionally targeted African-American and Latino neighborhoods by offering discriminatory mortgages to the minority borrowers and induced ridiculous defaults. The City charged that the Banks’ discrimination practice not only impaired the City’s efforts to ensure racial integration but also crippled its property tax revenue while at the same time raising the need for municipal services.
Major Issues Discussed
The main issue was whether Miami City allegations fell under the FHA and whether the banks knowingly caused unrest in the real estate in Miami leading to financial injuries to the city.
Appellant and Position
The city of Miami was the appellant. The City accused the Bank of America and Well Fargo Bank of racial misconduct which led to financial injuries. According to the court, foreseeability could not establish a clear connection between the alleged financial harm and the statute conduct concerning the FHA.
However, the court declined to draw clear boundaries of proximate cause. This was based on the facts deduced from the Hemi Group LLC v. City of New York case.
Appellee and Position
The appellee was the Bank of America and Well Fargo Bank. The banks did not deny the meaning of “aggrieved person” as defined by the FHA but argued that those words set boundaries that unfortunately are not clearly defined by the law.
They further stated that the court’s language in Gladstone, Havens Realty, and Trafficante was an exaggeration and unworthy to affect the final court decision, Legal Information Institute (2017).
Synopsis of Majority Opinion
The City of Miami did not allege that the defendants caused injury to it within the FHA statute nor did it represent any of the residents. Instead, the City theory claims were that from 2004 to 2012, the discriminatory mortgage-financing practices caused loan defaults, which led to loan terminations, which in return resulted in vacation of residents decreasing property values and that reduced property tax.
The court thus cleared that Miami’s alleged injuries were too remote to satisfy the proximate cause requirement of the FHA.
Justices in Majority: Justice Breyer and Justice Thomas.
Justices in Concurrence: Justice Kennedy and Justice Alito.
Synopsis of Minority Opinion
The minority argued that based on the Gladstone of the village’s asserted injury of reduced tax revenues, Miami’s case fell within the interests protected by the FHA. In Gladstone, the village plaintiff sued for a budget-related injury in addition to its racial injury.
As such, a financial related injury might be useful in establishing concrete evidence of injury by Article III but not to establish FHA’s interest boundaries.
Justices in Minority in part: Justice Kennedy and Justice Alito
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Legal Information Institute. (2017). Bank of America Corp. v. Miami ( ).