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

Perpetuation of segregation

There are three ways that perpetuation of segregation (fewer integrative moves permitted) were looked at. From the brief: “One set deals with the actual awards that were made; a second set looks at the pattern that would emerge if all apparently eligible households made the moves that they had applied for; and the third explores the results of a simulation of the lottery process run by defendant’s expert…In each of the six racial pairings, the outsider moves are, on net, more integrative than are the insider moves, on net. This is true for actual awards; it is true for the exercise in examining what would happen if all apparently eligible applicants moved to the development to which they applied; and it is true for the simulation.”

“[T]he undisputed data show that the net-integrative effect of nonbeneficiary moves was consistently substantially more than the net-integrative effect of CP-beneficiary moves (put the other way, the net-integrative effect of CP-beneficiary moves was substantially less than the net-integrative effect of non-beneficiary moves).This latter formulation is depicted in Chart 4, below.”