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Havens Realty Corp. v. Coleman | 455 U.S. 363 (1982)

Article Three of the Constitution permits federal courts to hear only actual cases or controversies, meaning to have standing, a plaintiff must allege an actual or imminent injury caused by the defendant. Courts may impose additional prudential standing limitations, like requiring the plaintiff to assert his own right within the zone of interest protected by the law. But as Havens Realty versus Coleman explains, Congress can override these prudential standing barriers.

Havens owned apartments in Henrico County, Virginia. Paul Coles, a Black man, tried to rent an apartment, but Havens told him there were none available. An organization called Housing Opportunities Made Equal, or HOME, sent Sylvia Coleman, a Black woman, and Kent Willis, a White man, to test whether Havens engaged in discriminatory renting practices. When Coleman and Willis each inquired, Havens told Coleman nothing was available but told Willis the opposite. Coles, Coleman, Willis, and HOME then sued Havens, each alleging injury caused by Havens’ racial steering in violation of the Fair Housing Act. Coles claimed Havens denied him the right to rent property. Coleman and Willis argued they sustained two injuries. First, Havens violated their right to truthful housing information. And second, Havens’ racial steering deprived them of the benefits of living in an interracial neighborhood. HOME claimed Havens impaired its efforts to provide effective residential counseling and referral services.

The district court dismissed the claims of Coleman, Willis, and HOME for lack of standing. Coleman and Willis were barred because they didn’t intend to rent. HOME lacked standing because the organization didn’t have rights under the Fair Housing Act. But the Fourth Circuit reversed, and the Supreme Court granted cert.

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