Boyd v. Lefrak Organization’s Empirical Analysis
509 F.2d 1110 · 1975
Citation profile
12 federal appellate · 4 district · 1 state decisions
How this case has been cited
Cited by 35 later decisions — most recently February 2025 · most notably 52 Cal. 3d 1142 - Harris v. Capital Growth Investors XIV (1991), Huntington Branch, National Ass'n for the Advancement of Colored People v. Town of Huntington (1988)
12 federal appellate · 4 district · 1 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 12 U.S.C. § 1715Z · 42 U.S.C. § 1982 (Civil Rights Act of 1866) · 42 U.S.C. § 2000A (Civil Rights Act of 1964) · 42 U.S.C. § 2000E (§ 701 of the Title VII of the Civil Rights Act of 1964) · 42 U.S.C. § 3601 (§ 801 of the Fair Housing Act (Title VIII, Civil Rights Act of 1968)) · 42 U.S.C. § 3604 (§ 804 of the Fair Housing Act (Title VIII, Civil Rights Act of 1968))
Relies on Griggs v. Duke Power Co. · Jones v. Alfred H. Mayer Co. · Trafficante v. Metropolitan Life Insurance · Jefferson v. Hackney · Lane v. Wilson
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A businessman’s differential treatment of different economic groups is not necessarily racial discrimination and is not made so because minorities are statistically overrepresented in the poorer economic groups. The fact that differentiation in eligibility rates for defendants apartments is correlated with race proves merely that minorities tend to be poorer than is the general population. In order to utilize this correlation to establish a violation of the Fair Housing Act on the part of a private landlord, plaintiffs would have to show that there existed some demonstrable prejudicial treatment of minorities over and above that which is the inevitable result of disparity in income, [cite omitted] Just as this court will not impose even on the government an affirmative duty to construct low-income housing when the decision not to build is not racially motivated, [cite omitted] so we will not impose an affirmative duty on the private landlord to accept low-income tenants absent evidence that his motivation is racial rather than economic in origin.”
3 later decisions quote this exact passage · from the majority“A landlord in the private sector is entitled to choose whom he will accept as tenants as long as he does not discriminate on one of the statutorily condemned bases. Certainly he may seek assurance that prospective tenants will be able to meet their rental responsibilities. “[Tjhere is no requirement that welfare recipients, or any other individuals, may secure apartments ... without regard to their ability to pay.””
2 later decisions quote this exact passage · from the majority“While blacks and Puerto Ricans do not have the same access to Lefrak apartments as do whites, the reason for this inequality is not racial discrimination but rather the disparity in economic level among these groups. While a showing of a disproportionate effect on nonwhites is sufficient to require application of the compelling state interest standard in the context of an equal protection challenge to government action, such an analysis is inappropriate in the context of a purely private action asserting a claim of racial discrimination. A businessman’s differential treatment of different economic groups is not necessarily racial discrimination and is not made so because minorities are statistically overrepresented in the poorer economic groups. The fact that differentiation in eligibility rates for defendants’ apart ments is correlated with race proves merely that minorities tend to be poorer than is the general population. In order to utilize this correlation to establish a violation of the Fair Housing Act on the part of a private landlord, plaintiffs would have to show that there existed some demonstrable prejudicial treatment of minorities over and above that which is the inevitable result of disparity in income. Just as this court will not impose even on the government an affirmative duty to construct low-income housing when the decision not to build is not racially motivated, so we will not impose an affirmative duty on the private landlord to accept low income tenants”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.