AFFIRMATIVELY FURTHERING FAIR HOUSING. Memphis Fair Housing Center – Memphis Area Legal Services Sapna V. Raj, Managing Attorney (901) 432-4663. Presentation Contents. Affirmatively Furthering Fair Housing Impediments to AFFH in Memphis. Affirmatively Furthering Fair Housing.
Memphis Fair Housing Center – Memphis Area Legal Services
Sapna V. Raj, Managing Attorney
Civil Rights Act
Handicap (physical/mental disability)
Recipients of federal funds
Programs and activities relating to housing and urban development
Analysis of impediments extends to all public and privately funded housing and housing-related activities in grantee’s jurisdiction
24 C.F.R. §91.225,325,425
Analysis of impediments involves an assessment of conditions - both public and private - affecting fair housing choice for all protected classes.
Impediments are actions, omissions or decisions which restrict housing choices or the availability of housing choices based on:
race, color, religion, sex, disability, familial status, national origin
Includes policies, practices, or procedures that appear neutral on their face
County is part of one of the wealthiest and most racially segregated regions in the country
AIs did not identify any impediments on the basis of any protected class
No mention of housing discrimination or residential segregation
County did not identify or analyze community resistance (NIMBY) to integration on the basis of race and national origin as an impediment.
AFFH means . . . to provide opportunities for inclusive patterns of housing occupancy regardless of race, color, religion, sex, familial status, disability and national origin
HUD Fair Housing Planning Guide at 1-3.
(includes attorney fees and “relator’s share”)
Providing more affordable housing for a low income racial minority will improve the minority’s housing stock but may do little to change pattern of discrimination or segregation
Addressing that pattern - necessitate an analysis of where the additional housing is placed.