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Abstract

This case note examines the United States Supreme Court's decision in Hills v. Gautreaux, 96 S. Cy. 1538 (1976), specifically the approval of a metropolitan area remedy as a valid form of federal relief. The case resulted from a class action suit against the Chicago Housing Authority (CHA) and the Department of Housing and Urban Development (HUD), alleging racially discriminatory public housing policies and practices. Although violations of the Fourteenth Amendment occurred within the Chicago city limits, the Supreme Court held that a metropolitan remedy which included the surrounding areas outside of the city boundaries was valid and that Milliken v. Bradley did not preclude this type of remedy. The case note highlights the Supreme Court's efforts at distinguishing Gautreaux from Milliken and suggests that the viability of metropolitan area remedies will depend on how far the Court is willing to resist the strictures of Milliken in future cases.

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