The Color of Law

federal appeals court ordered Black Jack to permit the pro-integration group to proceed. The court observed that hostility to the development was “repeatedly expressed in racial terms by persons whom the District Court found to be leaders of the incorporation movement, by individuals circulating petitions, and by zoning commissioners themselves.” The court continued: “Racial criticism [of the proposed development] was made and cheered at public meetings. The uncontradicted evidence indicates that, at all levels of opposition, race played a significant role, both in the drive to incorporate and the decision to rezone.” Citing similar cases from elsewhere in the country, the court concluded that Black Jack’s actions were “but one more factor confining blacks to low-income housing in the center city, confirming the inexorable process whereby the St. Louis metropolitan area becomes one that has the racial shape of a donut, with the Negroes in the hole and with mostly Whites occupying the ring.” The court further noted that Black Jack’s actions were exacerbating residential segregation that was “in large measure the result of deliberate racial discrimination in the housing market by the real estate industry and by agencies of the federal, state, and local governments.” This is de jure segregation.