Plaintiffs move for summary judgment against City in outsider-restriction case

Illustration of disparate impact on entrants

From the memorandum of law: This chart of entrants in the majority-White CD typology illustrates “the fact that benefit for one demographic group (Whites) is being combined with other effects going on at the same time for other demographic groups.”

“It is perhaps helpful here to underline a basic fact about defendant’s preference: without it, there would be no differentiation in the chart. With an equal-access lottery, the advantage-disadvantage bar for each set of insiders in a typology and each set of outsiders in a typology would lie at the 0.00 percent level (i.e., on the y-axis) because no artificial advantage or disadvantage was being conveyed as households applied (insiders and outsiders would not be differentiated).”