The Collaborative Center for Justice staff has submitted an objection to a proposed HUD rule that would significantly weaken fair housing protections. See our comment below. Click here to read our explanation of the public comment period, and click here to submit your own comment in opposition to the rule change by 11:59 p.m. on October 18.
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Re: HUD’s Implementation of the Fair Housing Act’s Disparate Impact Standard
Docket Number: FR-6111-P-02, RIN 2529-AA98
We are writing from the Collaborative Center for Justice, a faith-based advocacy organization in Hartford, CT. Our mission is to advocate for systemic change and educate individuals about social justice in order to make a difference in the lives of people who are poor and marginalized. Our work is rooted in the principles of Catholic Social Teaching and the lived experience of low-income people in Connecticut. We advocate for policies and practices that protect human and civil rights, and challenge discriminatory practices in our society.
We are deeply concerned about the impacts of this proposed rule, and we urge you to withdraw this proposal. Disparate impact is an important tool to address structural inequality and protect people from discrimination. We know that housing discrimination is not always explicit. Disparate impact is a tool by which to uncover and address experiences of housing discrimination that are not as obvious. This tool has been used widely all over the country for decades and its validity and importance have been upheld.
Specifically, in 2015 the Supreme Court ruled that disparate impact is a valid legal tool under the Fair Housing Act. This decision upheld that the Fair Housing Act was intended to protect people from the results of discrimination even when the discrimination was not intentional or explicit. This proposed rule would blatantly disregard this Supreme Court ruling. HUD should be working to uphold the Fair Housing Act, not undermine it.
Dismantling this tool would have wide ranging negative impacts on people around the country, and would be particularly impactful for people of color, women, families, and people with disabilities. The proposed changes would create enormous obstacles for people who have experienced discrimination to prove their claims. As people committed to protecting human and civil rights for all people, we are troubled by these proposed new hurdles. We are concerned that such barriers would heighten discrimination by impeding efforts to investigate and address claims of discrimination.
We are particularly concerned about how this proposed change would impact people of color and people with disabilities who are trying to find and maintain safe, affordable housing. We know that where someone lives has long lasting impacts on so many factors of one’s life, including access to quality schools, transportation, and employment possibilities.
As people of faith, we believe that each person is created in the image of God and deserves dignity and respect. We believe that fair, equitable access to safe, affordable housing is a human right. We stand firm in our belief that no one should be discriminated against because of their race, national origin, sex, familial status, religion, or disability. Creating policies that make it extremely difficult for individuals to stand up for their own rights and for fair treatment is contrary to the intent of the Fair Housing Act, and to the values of our country.
We strongly oppose this proposed rule and we urge you to withdraw it.
Thank you for the opportunity to comment.
Sincerely,
Dwayne David Paul – Director
Rachel Lea Scott, MSW – Associate Director
