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5 Harv. C.R.-C.L. L. Rev. 184 (1970)
Constitutional Law - Equal Protection - Racial Discrimination in Urban Renewal Program. Arrington v. City of Fairfield (5th Cir. 1969)

handle is hein.journals/hcrcl5 and id is 190 raw text is: CONSTITUTIONAL LAW-EQUAL PROTECTION-RACIAL DISCRIMI-
Recent urban renewal experience indicates that programs for relocation
of site residents have usually served to compound rather than alleviate
many social and economic problems relating to the housing of the poor.2
For example, when an urban renewal project redevelops a blighted or
slum area, the supply of low-rent dwellings available to poor people resid-
ing in the renewal area decreases, and it is often necessary for those dis-
placed to seek relocation housing far from their familiar communities.
Economically depressed black ghetto areas are often the first targets for
urban renewal programs, which have become known in many black com-
munities as Negro Removal programs. For blacks, racial discrimination
aggravates the already severe problem of finding comparable relocation
housing outside of the renewal area.3 Dislocated tenants will be forced to
crowd into whatever available housing their low incomes will allow, and
new slums of even greater proportions will arise outside of the renewal
The landmark decision in Norwalk CORE v. Norwalk Redevelopment
Agency 5 opened the door to judicial review of urban renewal relocation
plans.6 It established that residents of an urban renewal project have stand-
ing under federal law to assert that a relocation plan falls short of statu-
tory and constitutional standards. Standing was granted on two indepen-
dent theories. First, with the aid of Section 10 of the Administrative
' 414 F.2d 687 (5th Cir. 1969).
3 Hartman, The Housing of Relocated Families, in URBAN RENEWAL: THE
RECORD AND THE CONTROVERSY 293, 311 (J. Wilson ed. 1966).
4 In summarizing the plight of the black displacee, one commentator has said:
In the final analysis any relocation plan is dependent on an available supply of
housing, both public and private. To recognize the fact that relocation must
inevitably accelerate competition for an already inadequate supply of housing,
particularly for housing at levels that the bulk of relocatees can afford, and then
to proceed with relocation of families is to fly in the face of reason and reality.
This becomes doubly serious when Negroes are being relocated, since the competi-
tion for housing is most serious for the Negro, and further, a situation is created
largely by public action that results in pressures upon the social fabric without an
assumption of responsibility for coping with the effects of these pressures.
Meltzer, Relocation of Families Displaced in Urban Redevelopment: Experience in
Woodbury ed. 1953).
s 395 F.2d 920 (2d Cir. 1968), noted in 82 HARV. L. REV. 691 (1969) and 4
HARV. CIV. RIGHTS-CIV. LIB. L. REV. 176 (1968).
6 See generally Note, Family Relocation in Urban Renewal, 82 HARV. L. REV.
864 (1969); Note, Judicial Review of Displacee Relocation in Urban Renewal, 77
YALE L.J. 966 (1968).

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