Continued lack of affordable housing in Chicago’s northern suburbs

Affordable housing is a problem throughout the Chicago region but here is a closer look at the current state of affordable housing in Chicago’s North Shore suburbs:

Under the law, the Illinois Housing Development Authority in 2004 identified 49 communities where less than 10 percent of the housing was deemed affordable. At least nine of them are on the North Shore, including Winnetka, Wilmette, Highland Park, Deerfield, Northbrook, and Lake Forest.

Reactions to the law varied in those communities. Highland Park aggressively pursued ways to make affordable housing available. Northbrook took a more casual approach and set general goals. In Winnetka, after years of heated debate, officials voted in 2011 to just stop talking about the issue…

But over the last ten years, the affordable housing that has been added “is a drop in a bucket,” she said.

“The economy is bouncing back, but a lot of these communities are still catering to the rich,” said Schechter.

A significant barrier for affordable housing in the North Shore is the lack of undeveloped land and the high price of properties, said Richard Koenig, executive director of the Housing Opportunity Development Corporation.

It doesn’t look to me like much has changed. The 2004 Illinois law hasn’t done much as many communities already met the requirements (based on a formula that may then be too lax), it has little ability to enforce anything, and there are still continuing issues of affordable housing. I think there is also some disconnect about who the affordable housing is supposed to serve. In my experience, when suburbs like those on the North Shore talk about affordable housing, they are more willing to do something when they are talking about public servants, like teachers, police officers, and firefighters, or people who have been in the community before, like kids who grew up in the suburb or retired residents, who have difficulty living there on limited incomes. These suburbs are not thinking as much about the retail or service industry or laborers that might work in their communities.

This shouldn’t be too surprising: given the opportunity, most wealthier suburbs will zone land in such a way that the housing prices and options cater to a wealthier crowd. Affordable housing is an issue that should be taken care of by other suburbs, such as more working- or lower-class communities.

Sociologist James Loewen continues to educate about sundown towns

Sociologist James Loewen has made a career of instructing Americans about the real racial history of the country. He continues to educate people about his findings laid out in Sundown Towns:

By not parrying the South’s attempts to further racism, the North placated the South. In fact, the South began building memorials because, in philosophy, they did win the Civil War. One reason northern states withdrew their efforts was the fact that they were already ridden with Sundown towns, especially in the Midwest. As stated before, Sundown towns gained their reputation from attempting to drive out their black population by dark.

“More than half of towns in the Midwest were Sundown towns,” Loewen said.

In fact, the reputation of former Dearborn mayor Orville L. Hubbard, whose statue stands in front of City Hall, comes from his dedication to maintaining a Sundown Town in Dearborn.

Remnants of Sundown Towns in Detroit are observable today in former residences such as the Orsel McGhee household located at 4626 Seebaldt Ave. The Orsel Mc-Ghees were an African-America family that attempted to moved into a segregated, white neighborhood of Detroit in 1944 but were forced to move after a lawsuit was brought against them.

Another case was the Ossian Sweet case, where Sweet, a black doctor, attempted to defend his home against a white mob that sought to drive him out of a white segregated community on Sept. 9, 1925. A 1985 Dearborn ordinance, passed by an overwhelming white majority vote, made city parks off-limits to non-residents, a measure created to prevent black would-be homeowners from moving in. Loewen also spoke about Anna, Ill., circa 1909. White residents, with the help of local government officials, began to force out blacks and Anna became an acronym for “Ain’t no N Allowed.”

One fairly recent, yet baffling, example that Loewen presented was the case of Villa Grove, Ill. Until 1999, Villa Grove sounded a siren every day at 6 p.m. to warn blacks to leave the city. Similar problems were prevalent in the 1970s despite the Supreme Court’s “Shelley v. Kraemer” ruling stating that state courts could not enforce a restrictive covenant. In this context, a restrictive covenant is a clause in a deed that limits to whom a property can be leased or sold.

Not too many communities are interested in sharing these parts of their history. Loewen’s findings are all the more shocking when he makes clear that this was common across northern communities, places that many Americans learn and think were more open to blacks than Southern communities.

Even though sundown towns are no longer with us, sociologists argue these more formal rules have been replaced by more informal means of keeping minorities and lower class residents out of suburbs. One common technique is exclusionary zoning, a practice where communities only allow larger and more expensive homes to be built. Without much affordable housing, employees in lower income jobs, ranging from municipal workers to retail and service jobs, often cannot live near their suburban jobs and then must also maintain a car, an expensive proposition in itself.

Opposition to permanent supportive housing for the mentally ill in the Chicago suburbs

With the public discussion of mental illness in recent days, here is a look at trying to build housing for the mentally ill in the Chicago suburbs:

She would like to find a place close by, a place that’s affordable, a place that would provide independence and easy access to needed social services.

But local social service agencies and advocacy groups say that kind of housing — often referred to as permanent supportive housing — is rare in the suburbs…

Chicago-based Daveri Development Group, with help from agencies like the North/Northwest Suburban Task Force on Supportive Housing for Individuals with Mental Illness, has submitted three proposals during the past several years for supportive-housing developments in the suburbs — one in Arlington Heights, one in Mount Prospect and one in Wheeling.

Mount Prospect leaders approved Daveri’s plan in November 2011. That project, known as Myers Place, is expected to open at Dempster Street and Busse Road in the spring or summer of 2013.

The other two proposals, after encountering stiff resistance from neighbors, were rejected.

Many critics of those plans said the same basic thing: good concept, bad location.

The article goes on to talk about how several of these cases have gone to court. Despite the claims of opponents that their reactions are not based on fear, it is hard not to see this as a NIMBY situation: suburbanites living in typical subdivisions wouldn’t want such facilities near them. Saying it is a zoning issue sidesteps the problem; zoning is all about making sure different uses don’t mix and is often wielded in suburbs to protect more exclusive residential neighborhoods.

This leads to an interesting dilemma: what if the average suburbanite thinks such facilities would be good for helping deal with mental illness but no one wants to live near them?

Brookings report: zoning laws help lead to school achievement differences

A new report from the Brookings Institution suggests that zoning laws are behind differences in school achievement:

The report found that students from poorer households tend to go to schools where scores on state standardized tests are lower while more affluent students tend to go to schools with higher test scores. The findings confirm what numerous studies and a recent Sun analysis have also found.

The average student from a low-income family in Las Vegas attended a school that tested in the 43rd percentile. The average student from a middle- or high-income family went to a school that scored in the 66th percentile, according to the report, which used state test score data listed on…

Rothwell’s research went further than other studies that looked at socioeconomic data and school performance, however. His report is among the first looking at how zoning policies affect home prices and student access to high-quality schools.

Rothwell argues municipal zoning policies that restrict affordable housing have segregated students from low-income families from their more affluent peers, creating achievement gaps in schools.

Where people can live matters. We tend to have the idea in America that anyone can live anywhere. Theoretically, this is true but economically, this is not possible as it takes quite a bit of money to move to areas with better amenities like high-performing schools. Zoning plays into this by giving local governments control over how land is used. If communities decide that land can only be used for more expensive single-family housing, then housing options are limited. The summary of the full report sums it up this way:

Across the 100 largest metropolitan areas, housing costs an average of 2.4 times as much, or nearly $11,000 more per year, near a high-scoring public school than near a low-scoring public school. This housing cost gap reflects that home values are $205,000 higher on average in the neighborhoods of high-scoring versus low-scoring schools. Near high-scoring schools, typical homes have 1.5 additional rooms and the share of housing units that are rented is roughly 30 percentage points lower than in neighborhoods near low-scoring schools.

Large metro areas with the least restrictive zoning have housing cost gaps that are 40 to 63 percentage points lower than metro areas with the most exclusionary zoning. Eliminating exclusionary zoning in a metro area would, by reducing its housing cost gap, lower its school test-score gap by an estimated 4 to 7 percentiles—a significant share of the observed gap between schools serving the average low-income versus middle/higher-income student. As the nation grapples with the growing gap between rich and poor and an economy increasingly reliant on formal education, public policies should address housing market regulations that prohibit all but the very affluent from enrolling their children in high-scoring public schools in order to promote individual social mobility and broader economic security.

A fascinating argument: eliminating some of the zoning differences across communities would reduce the educational achievement gap. However, zoning is at the heart of local government and municipalities don’t give this up easily.

How small is too small for a new house? Debating minimum sizes (along with race and class)

There are plenty of people who would like to see Americans live in smaller homes but some communities have minimum square footage requirements for new homes, leading to this question: how small is too small for a new house?

Chris Jaussi, owner of Zip Kit Homes in Mount Pleasant, manufactures homes as small as 400 square feet and would like to sell the micro dwellings in the county. But dwellings that small are prohibited by a 1980s ordinance that mandates the minimum size [800 square feet] of a residence…

He believes the current ordinance is “discriminatory” against lower-income people who can’t afford a conventional “stick-built home” in the county…

County officials said the existing policy was adopted to limit mobile and double-wide manufactured homes to specified zoned areas and keep them from springing up randomly in the county…

“I have a lot of sympathy for those who can’t afford their own homes — the poor of Sanpete County. But I don’t want to make housing so cheap we import the poor from other cities,” said Stewart [vice chair of the county’s Planning and Zoning Commission], according to the newspaper. “We get someone who can’t afford to build a bigger home, so they buy this one and fill up the rest of the [5-acre county lot] with junk cars …we don’t want people to come to Sanpete County for that reason.”

This is fascinating for a couple of reasons:

1. Many residents may not think about minimum or maximum home sizes – can’t you build what you want on your own property? However, zoning laws are often quite clear about this.

2. I don’t think minimum home sizes are that unusual. It sounds like this was enacted in this particular county to limit manufactured homes but I also have read about a similar battle in Naperville. Levitt and Sons, the same builders who built the famous Levittowns in the Northeast, proposed building smaller homes of about 1,000 square feet in the early 1980s. However, residents of nearby newer subdivisions complained that the much lower prices of these “downsized” homes would reduce their own property values. Naperville thought about enacting a minimum size ordinance but decided not to after finding that similar regulations in other Chicago suburbs had been struck down in court.

3. Let’s be honest here: this is all about property values and of course, property values also coincide with issues of race and class. More expensive homes, which on average are more likely to attract middle- to upper-class residents who are more likely to be white, are seen by many communities as a boon while smaller homes which attract the lower classes and minorities are seen as less worthwhile. Look at the associations cited here in this story: allowing smaller homes will automatically attract lower-income residents who will live in mobile homes and/or keep junked cars in their yards. The suburbs have a long history of formal and informal ways of restricting access to the poor and a minimum house size or lot size (usually associated with exclusionary zoning) can accomplish this. I do wonder though if these smaller homes will necessarily attract low-income residents – if these smaller homes are about being green (and perhaps also about quality rather than quantity), might they also be marketed to more educated, higher-class residents?

Does the failure of urban renewal necessarily mean that the free market could solve the problems of poor neighborhoods?

Reason looks at what happened to one New York City neighborhood in the name of urban renewal:

In 1949, President Harry Truman signed the Housing Act, which gave federal, state, and local governments unprecedented power to shape residential life. One of the Housing Act’s main initiatives – “urban renewal” –  destroyed about 2,000 communities in the 1950s and ’60s and forced more than 300,000 families from their homes. Overall, about half of urban renewal’s victims were black, a reality that led to James Baldwin’s famous quip that “urban renewal means Negro removal.”

New York City’s Manhattantown (1951) was one of the first projects authorized under urban renewal and it set the model not only for hundreds of urban renewal projects but for the next 60 years of eminent domain abuse at places such as Poletown, New London, and Atlantic Yards. The Manhattantown project destroyed six blocks on New York City’s Upper West Side, including an African-American community that dated to the turn of the century. The city sold the land for a token sum to a group of well-connected Democratic pols to build a middle-class housing development. Then came the often repeated bulldoze-and-abandon phenomenon: With little financial skin in the game, the developers let the demolished land sit vacant for years.

The community destroyed at Manhattantown was a model for the tight-knit, interconnected neighborhoods later celebrated by Jane Jacobs and other critics of top-down redevelopment. In the early 20th century, Manhattantown was briefly the center of New York’s black music scene. A startling roster of musicians, writers, and artists resided there: the composer Will Marion Cook, vaudeville star Bert Williams, opera singer Abbie Mitchell, James Weldon Johnson and his brother Rosemond, muralist Charles Alston, writer and historian Arturo Schomburg, Billie Holiday (whose mother also owned a restaurant on 99th Street), Butterfly McQueen of “Gone with the Wind” fame, and the actor Robert Earl Jones.

Designating West 99th and 98th Streets a “slum” was bitterly ironic. The community was founded when the great black real estate entrepreneur Philip Payton Jr. broke the color line on 99th Street in 1905. Payton, also credited with first bringing African Americans to Harlem, wanted to make it possible for a black man to rent an apartment, in his words, “wherever his means will permit him to live.”

While Reason is a conservative website, there are plenty of others on the other side of the political aisle that also agree that urban renewal had a negative impact on many neighborhoods. Ultimately, this policy was used to clear “slums” and to use that land for more profitable development, typically for wealthier residents and businesses. Additionally, what actually counted as “blight” or as a “slum” was contentious as it tended to frown upon cheaper, ethnic or non-white neighborhoods. Blacks weren’t the only ones displaced; Herbert Gan’s classic work Urban Villagers looked at the fate of an Italian-American neighborhood which was ripped apart by urban renewal.

Since this comes from Reason, I assume that this is a critique of liberal policy and of eminent domain: you can’t trust the government with these kinds of powers as they will use it to trample people they don’t like. But can we swing all the way in the opposite direction and suggest that the free market will eventually get rid of the issues that poorer neighborhoods face and that lead them to be ripe for urban renewal?

I would argue no. Left to its own devices, the free market can also result in harmful policies that hurt less than wealthy neighborhoods. Here are a few examples:

1. Redlining. This was based on the practice of marking urban neighborhoods in terms of the security of their real estate by the Home Owners’ Loan Corporation which arose out of the New Deal. But this practice really took off when private lenders and institutions adopted the government agency’s markings and then only made loans to the better neighborhoods, effectively shutting out poor neighborhoods from mortgages.

2. Exclusionary zoning. After the Fair Housing Act of 1968 ruled out discrimination in the sale or rental of housing, exclusionary zoning became a hot topic in the 1970s. A number of court cases looked at how the zoning guidelines of communities and counties effectively kept poor people out of suburban locations. By only allowing higher priced housing or certain kinds of housing (like single-family homes on a minimum of 2 acres), these zoning guidelines were very effective in maintaining the exclusivity of certain areas.

3. Still existing discrimination in obtaining mortgages and other loans. There have been plenty of studies that show when equally matched whites and blacks apply for a mortgage or a car loan or another loan, blacks are rejected at higher rates. Similar research has shown this also applies to jobs. Read an overview of this research in a 2008 Annual Review of Sociology article.

4. The ongoing presence of residential segregation in the United States. Many of our major cities, particularly in the Northeast and Midwest, are still very segregated. View maps of some of these cities here.

5. Gentrification. While the influx of residents may “improve” a neighborhood, it often has the effect of pushing the poorer residents into other poor neighborhoods because of increased housing prices and property taxes.

So urban renewal was not the answer. But it is unlikely that a completely unfettered free market is as well. So perhaps the real question to address is how to craft effective public policy that provides aid to neighborhoods and their residents so that these neighborhoods truly improve, add jobs, and experience revitalization. The key here is “effective,” policy that does not become cost prohibitive, works with local residents and organizations rather than just applies a top-down approach, and achieves attainable and worthy objectives while minimizing unintended consequences. This is likely a difficult task but swinging the pendulum all the way to the free market side isn’t the solution.

“Zoning bigots” holding Americans back from how they really want to live?

It is not too often that one sees opinion pieces about the current state of zoning in America. But here is some provocative commentary (“zoning bigots”?) based on zoning in the Los Angeles area:

You could make a decent case that the campaign to harass and remove property owners is no less bigoted than Mayor Mahool’s quarantine proposal. Although blacks, whites, and Latinos have all been targeted for nuisance abatement raids, these folks share one characteristic: They don’t meet the standards of respectability set by the political class and large urban landowners. In some cases the county’s lifestyle demands shade into bias on religious grounds. Oscar Castaneda, a mechanic and Seventh Day Adventist minister who was ordered to tear down his entire property, lives in the high desert because his faith impels him to a rural, self-sufficient life.

Los Angeles zoning practice is bigoted in other ways that are often overt. A city (not county) ordinance preventing residents from keeping more than one rooster on a property is clearly aimed at Latino homeowners. A maze of restrictions on convenience stores and fast food joints applies in South L.A. but not in tonier areas. During the jihad against “McMansions” a few years ago, the popular term for large properties was “Persian Palaces”—a swipe at L.A.’s Iranian-American community.

“There’s definitely an attempt to squeeze out of Angelenos the very things that make them Angelenos and not New Yorkers or Bostonians,” says Chapman University urban theorist Joel Kotkin. “There are two forces at work: One is the effort to re-engineer people into wards of the state. The other is urban land interests who want to force people to live in ways they don’t want to live.”

Or to live somewhere else. Many of the Antelope Valley homeowners we spoke with for a recent report have given up the struggle and are planning to leave California. What Antonovich (who refused requests for an interview) has in mind for their vacated properties is not clear. Educated guesses include a plan for massive wind-power generation and a scheme to turn the half-horse town of Palmdale into a high-density, smart-growth hub for the California high-speed rail project. If you know Palmdale you know that the notion of turning it into a hipster paradise would be funny—except that this pipe dream is destroying the lives of real people. They’re just not the right sort of people.

A few thoughts while trying to sort out this argument:

1. Good point: zoning can be a tool used by the powerful (politicians, those with money, etc.) to control development. The political economy model in urban sociology is based on this idea: the elite are able to push development that helps make them money.

2. Odd point: this argument about “bigoted zoning” is somewhat different from a more common argument about “exclusionary zoning.” This argument is predicated on the idea that zoning takes away the rights of all individuals, regardless of race/ethnicity or social class. It is simply a tool of the upper classes, interestingly, a Marxist type argument. Exclusionary zoning, the subject of a number of court cases, argues that zoning takes place to exclude certain groups of people, typically minorities and the lower class from suburbs. So all individuals who are not the upper class are being discriminated against in this Marxist/populist argument?

3. Somewhat intriguing argument: these zoning guidelines limit people from doing what they really want to do, like buy McMansions and raise chickens. In this line of thinking, Americans all want the suburban lifestyle where their home is their castle and they have a little bit of land to play around with. The government is a bogeyman, trying to force people into denser developments (like nice New Urbanist developments or high-rises downtown?) and generally trying to squelch suburban life.

This argument misses some of why the suburbs even exist in the United States today. On one hand, there is some cultural impetus to this all: from the beginning, Americans have had debates about urban vs. rural life, the Thomas Jefferson’s who wanted “gentlemen farmers” versus the Alexander Hamilton’s who wanted to live in thriving cities. Americans like open space and retained the British emphasis on property rights. This cultural spirit is still with us today: we love cars and our big homes.

However, this was all made possible and encouraged by some other factors. To start, developing technologies, from the railroad to the electric streetcar to the automobile, opened up areas for development. More importantly, developers and businessmen saw these transportation lines and the adjacent land as opportunities so they sold homes and land to make money. Then, particularly between the 1930s and 1960s, the government made a concerted push to promote the suburban lifestyle, privileging highway construction and longer-term mortgages that helped make the suburban dream possible. Without this profit seeking and government support, would the suburbs have still happened? Perhaps. But not likely to the scale we know now.

To argue now that generally government is opposed to the suburban life is silly. Most of the policies, even during this time of economic crisis, have been about maintaining the suburban middle-class lifestyle: limiting their tax burden, helping them keep their homes, ensuring a quality education and a college degree, etc. Yes, this current administration has suggested some new ideas like high-speed rail but this isn’t a total assault on the suburbs. Indeed, it would be tough for any party right now to assault the suburbs too strongly: they probably can’t win without suburban voters, particularly independents.

4. Flip this around: what might happen if there is no zoning? Does this really empower individual land owners? Zoning helps ensure that certain uses are not next to other uses. For example, zoning for a suburban subdivision typically means that a single-family home will not end up next to a coal power plant. Or a school next to a sewage treatment plant. Yes, zoning can be draconian and it can be used by people in power but it can also be used well.

There are cities that have less or no zoning. Houston is a classic example in urban sociology and as one might suspect, its development patterns look a bit different than other major cities.

Is no zoning really the answer? While homeowners might not like some of the plans in the Los Angeles region, doesn’t it also protect them at other times? In a world with no zoning, wouldn’t the more powerful actors almost always win out over the average homeowner? How would homeowners protect themselves from other homeowners?

One way to retain zoning but turn it toward different ends would be for citizens to get themselves on zoning boards and then starting voting how they like. Zoning boards may not be flashy and it can be difficult to get on them, particularly in places where it is about political connections, but this would be the place to start fighting back if one was inclined to do so.

Problems at the DuPage Housing Authority

As part of a story about corruption at the DuPage Housing Authority, the Chicago Tribune provides an update on the recent history of the organization:

But investigators have asked plenty of questions lately about how DuPage housing officials spend the $22 million in federal funds they get annually.

Since 2009, the U.S. Department of Housing and Urban Development has audited the DuPage Housing Authority three times, concluding the troubled agency violated numerous federal regulations and must pay back $10.75 million in misused tax money.

HUD has determined DuPage must repay that money to its Section 8 housing program because it didn’t allow competition for projects, failed to properly document whether many tenants were eligible to get subsidized rent, made inappropriate credit card purchases and, in some cases, overpaid benefits.

This is not a whole lot of federal money, particularly in a county with a population over 900,000 and a poverty rate of around 6% (this site has 2009 figures of a poverty rate of 6.5% and the 2008 Census had an estimate of 5.8%). But the DuPage Housing Authority has an interesting history. If I remember correctly from research I have done, the group was formed in the 1940s and had some federal money to work with. But by the early 1970s, the Housing Authority had not built any units within the county and HOPE, an organization now in Wheaton, sued the county for housing discrimination, primarily for exclusionary zoning practices. The court case, Hope v. County of DuPage (the 1983 version here), lasted for over a decade and here is a brief summary of the conclusion in a law textbook.  It is only within recent decades that the Housing Authority has developed units.

This is perhaps not too unusual considering the political conservatism of a county that has been solidly Republican since the the 1860s. But as the lawsuit from the early 1970s alleged, the county has continued to change: more immigrants and minorities have become residents, housing values went up, a number of communities limited construction of apartments, and there are a good number of lower-paying jobs in wealthier communities. Add this all up and there are affordable housing concerns within a wealthy county and this extends beyond the common suburban debate about “work-force” housing for essential government employees like teachers or policemen or providing cheaper housing for young graduates and/or older residents.

Lawsuit over “super-majority white neighborhoods” in Atlanta suburbs

Atlanta is often held up as an example of Southern sprawl. The Atlanta Journal-Constitution reports on a new lawsuit filed against some recently created suburban communities north of Atlanta:

The Georgia Legislative Black Caucus filed a lawsuit Monday against the state of Georgia seeking to dissolve the city charters of Dunwoody, Sandy Springs, Johns Creek, Milton and Chattahoochee Hills…

The lawsuit, filed in a North Georgia U.S. District Court Monday, claims that the state circumvented the normal legislative process and set aside its own criteria when creating the “super-majority white ” cities within Fulton and DeKalb counties. The result, it argues, is to dilute minority votes in those areas, violating the Voting Rights Act of 1965 and the Fourteenth and Fifteenth Amendments to the Constitution…

Sandy Springs, created in 2005, is 65 percent white and 20 percent black. Milton, formed a year later, is 76.6 percent white and 9 percent black. Johns Creek, also formed that year, is 63.5 percent white and 9.2 percent black. Chattahoochee Hills, formed in 2007, is 68.6 percent white and 28 percent black, while Dunwoody, created in 2008, is 69.8 percent white and 12.6 percent black.

Emory University law professor Michael Kang said the case is unique because the Voting Rights Act focuses on redistricting, whereas this lawsuit challenges the legality of cities. Kang, who has not reviewed the case in its entirety, said the plaintiffs will likely have to show evidence of discriminatory purpose to have a strong claim. Kane said the case has interesting implications.

“If we look at this realistically, there is some white flight going on. The creation of these Sandy Springs-type cities enables white voters to get away from black voters,” he said. “It does strike me that the Voting Rights Act might have something to say about this, but it’s unknown what the courts will say about it.”

There is little doubt that there are exclusionary practices that take place in suburban communities, whether this is through zoning for particular uses (typically to avoid apartment buildings or lower-income housing – read about a recent debate over this in Winnetka, Illinois) or high real estate prices.

But the idea that incorporation itself is exclusionary is an interesting idea. Certainly, this is done along class lines: wealthier communities have incorporated in order to help protect their status and boundaries. Cities and suburbs have a long history of annexation in order to expand their own boundaries and their tax base (see this argument that Detroit should annex surrounding areas to help solve some of its problems). But was this done intentionally in regards to race (as opposed to just class or other issues) in these Atlanta suburbs? And what sort of evidence would a court find persuasive in this argument?