Bank of America Corp. v. Miami

A city is an “aggrieved person,” authorized to bring suit under the Fair Housing Act (FHA), according to the Supreme Court. The City of Miami sued Bank of America and Wells Fargo, alleging violations of the FHA prohibition of racial discrimination in connection with real-estate transactions, 42 U.S.C. 3604(b), 3605(a). The city claimed that the banks intentionally targeted predatory practices at African-American and Latino neighborhoods and residents, lending to minority borrowers on worse terms than equally creditworthy nonminority borrowers and inducing defaults by failing to extend refinancing and loan modifications to minority borrowers on fair terms, resulting in a disproportionate number of foreclosures and vacancies, impairing municipal effort to assure racial integration, diminishing property-tax revenue, and increasing demand for police, fire, and other municipal services. The Court reasoned that those claims of financial injury are “arguably within the zone of interests” the FHA protects. In remanding the case, the Court stated that the Eleventh Circuit erred in concluding that the complaints met the FHA’s proximate-cause requirement based solely on a finding that the alleged financial injuries were foreseeable results of the banks’ misconduct. Foreseeability alone does not ensure the required close connection to the prohibited conduct. Proximate cause under the FHA requires “some direct relation between the injury asserted and the injurious conduct alleged,” considering the “nature of the statutory cause of action,” and an assessment “of what is administratively possible and convenient.” View "Bank of America Corp. v. Miami" on Justia Law