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El Cortez Heights Residents & Property Owners Ass'n v. Tucson Housing Authority

Citations: 10 Ariz. App. 132; 457 P.2d 294; 1969 Ariz. App. LEXIS 539Docket: No. 2 CA-CIV 588

Court: Court of Appeals of Arizona; July 18, 1969; Arizona; State Appellate Court

Narrative Opinion Summary

In this case, the El Cortez Heights Residents and Property Owners Association filed for preliminary and permanent injunctions against the Housing Authority of the City of Tucson, challenging a low-cost housing project planned in a racially diverse, primarily Black middle-income neighborhood. The plaintiffs argued that the site selection process, which they claimed was conducted without due consideration of racial demographics, perpetuated racial isolation and violated constitutional rights. Despite the Housing Authority's assertions of compliance with federal mandates, including Executive Order No. 11063 and Title VI of the Civil Rights Act of 1964, the trial court denied the injunctions. On appeal, the court focused on federal regulations prohibiting racial discrimination in site selection, emphasizing the necessity of considering racial composition to prevent discriminatory outcomes. The appellate court reversed the trial court's decision, underscoring that awareness of racial factors is indispensable in public housing site selection. The decision reflects the evolving judicial interpretation of non-discrimination principles in federally funded housing projects, referencing recent rulings that permit race-based considerations to achieve equality.

Legal Issues Addressed

Consideration of Racial Composition in Housing Site Selection

Application: The court highlighted the necessity for housing authorities to consider racial composition in site selection under federal regulations, emphasizing that ignoring racial factors contradicts regulatory mandates.

Reasoning: The Tucson Housing Authority must not ignore racial factors in site selection, as doing so contradicts the mandates of the regulations.

Judicial Reversal Based on Racial Considerations in Public Housing

Application: The appellate court reversed the trial court's judgment, indicating that racial considerations are crucial in the site selection process for low-income housing.

Reasoning: The judgment was reversed, with references to relevant cases and literature for further context.

Non-Discrimination Mandates in Federally Funded Housing

Application: The case examines the application of Executive Order No. 11063 and Title VI of the Civil Rights Act of 1964, which prohibit racial discrimination in federally funded housing programs.

Reasoning: Executive Order No. 11063 initiated this requirement, followed by Title VI of the Civil Rights Act of 1964, which prohibits discrimination based on race, color, or national origin in federally funded programs.

Preliminary and Permanent Injunctions in Housing Disputes

Application: The plaintiffs sought both preliminary and permanent injunctions against the housing project, which were denied by the trial court, leading to an appeal.

Reasoning: The El Cortez Heights Residents and Property Owners Association (plaintiffs) sought a preliminary injunction against the Housing Authority of the City of Tucson (defendants) concerning a low-cost housing project in their area, which was also framed as a petition for a permanent injunction.

Role of Federal Regulations in Preventing Discriminatory Housing Practices

Application: Regulation 1.4 was referenced as prohibiting the use of site selection criteria that result in racial discrimination, thus impacting the court's analysis of the housing authority's practices.

Reasoning: Regulation 1.4 prohibits recipients of federal funds from using criteria in site selection that lead to racial discrimination.