emotional harm in housing discrimination casesemotional harm in housing discrimination cases

Accepting Cryptocurrency and Digital Asset Donations: What Charities Need to Know. of Tex., 133 S. Ct. 2411, 2420 (2013) (quoting Wygant v. Jackson Bd. 1994) (citing Feeney). [18] Dep't of Justice and Dep/'t of Educ., "Dear Collegue" Letter on the Nondiscriminatory Administration of School Discipline (Jan. 8, 2014), available at http://www2.ed.gov/about/offices/list/ocr/letters/colleague-201401-title-vi.html. Tumawag sa (808-586-8844) para sabihin kung anong lengguwahe ang nais ninyong gamitin. [4] Note that the analysis under these civil rights law are not always the same, particularly to the extent that the Equal Protection Clause affords different levels of protection to classifications based on sex and disability vs. race, color, and national origin. They may even cite to Cummings when arguing that a case seeking only emotional distress damages does not have Article III standing in federal court. Admr of Mass. WebReputational harm. Part II discusses the issue of bias in the process of emotional harm in housing discrimination cases Id. In these cases, one means of proving intentional discrimination is through circumstantial evidence showing a statistical disparity that affects a large number of individuals. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. WebThere are no empirical studies that adequately explain how and why decision-makers value emotional harm in housing discrimination cases in a manner that differs so greatly from the victim's experience and the scientific evidence of the effects of trauma resulting from discrimination. June 5, 2019 / 12:15 PM / CBS Colorado. Direct Evidence of Discriminatory Intent. In a case alleging such pervasive or systemic discrimination, the plaintiff need not initially show discrimination against any particular person; rather the critical showing at the prima facie stage is one of a pervasive policy of intentional discrimination affecting many individuals. See Teamsters, 431 U.S. at 360; Chin v. Port Auth. Adarand, 515 U.S. at 22324 (1995); Grutter, 539 U.S. at 326. b. N.C. State Conf. With the United States Supreme Court's condemnation of legal segregation in Brown v. Board of Education in 1954, and a vigorous civil rights movement that led to the passage of the 1964 Civil Rights Act, the nation entered the beginning of a new era in race relations. U. RB. Statement in compliance with Texas Rules of Professional Conduct. at 362 n.50 (citing McDonnell-Douglas, 411 U.S. at 80406). 1994) (citing, whether the facts proved are sufficient to, Arlington Heights factors, such as history, 284 F. Supp. Statistics showing racial or ethnic imbalance are probative in pattern or practice cases because a clear and significant imbalance based on race or ethnicity is often an indication of purposeful discrimination. No. Complaint Resolution Letter, Richmond Heights School District (OH), No. The first chapter of each consumer law treatise is available for freein NCLC's Digital Library. Agencies can use the McDonnell-Douglas framework for investigations involving the selection of individuals, such as for program participation, benefits, or services, particularly where the recipient provides a nondiscriminatory explanation for its decision. Columbus Bd. [12] Absent a stark pattern, then, discriminatory intent requires more than discriminatory impact. Strict scrutiny requires that the decision-maker ultimately be satisfied that no workable race-neutral alternatives would further the compelling interest about as well and at tolerable administrative expense. Fisher v. Univ. [16]The elements of a prima facia case are the same under both Title VI and VII. In light of this heightened risk of harm, transgender individuals have reason to take threats of violence seriously, stated Dr. Stotzer. Sch. United States v. The Dorchester Owners Association, 2023 WL 413580, (E.D. As a subscriber, you have 10 gift articles to give each month. Off. EEOC v. Boeing Co., 577 F.3d 1044, 1049 (9th Cir. Secure .gov websites use HTTPS 1, 551 U.S. 701, 720 (2007). Under this model, agencies do not shift the evidentiary burdens between complainant and recipient when making findings. WebEEOC EMOTIONAL DISTRESS AWARDS . Nuevos Medios de Pago, Ms Flujos de Caja. Absent more tangible forms of harm, emotional distress is often In Teamsters, the employer used job transfer policies that punished individuals, primarily minorities, who tried to transfer from less desirable jobs to more desirable ones. Impact evidence. 2012) (class action alleging pattern or practice of racial profiling by law enforcement agency in violation of Title VI and the Fourth and Fourteenth Amendments); Dept of Justice, Investigation of Los Angeles County Sheriffs Department Stations in Antelope Valley (June 28, 2013) (Title VI pattern or practice violation). Attorney Advertising Notice: Prior results do not guarantee a similar outcome. 113, 119 (2d Ci. Accordingly, when viewed collectively, the evidence in the record established intentional discrimination based on race. Other than instances where a recipient uses race expressly to achieve diversity or implement a race-based remedy for past discrimination, finding direct evidence is rare; most recipients are circumspect enough to avoid making overtly discriminatory statements. Agency regulations further state that recipients may not administer their programs or activities in a manner that den[ies] any individual any disposition, service, financial aid, or benefit provided under the program, 28 C.F.R. suffers from depression but his health has made significant progress with the help of cats in their home. Kokori (808-586-8844) omw kopwe ureni kich meni kapas ka ani. By 26 May 2022 usc marshall drop in advising 26 May 2022 usc marshall drop in advising (The Title VI Legal Manuals disparate impact section discusses this requirement in detail.) "This is a case that's really important to spread the word that individuals with disabilities, even disabilities we can't see, we can't pinpoint, we don't know what they are until they disclose them to us," she said. A clean direct evidence casewhere direct evidence alone establishes that discrimination was the sole reason for an adverse decisionis rare. Guidance. A federal judge found that the only injuries Ms. Cummings had suffered were humiliation, frustration and emotional distress and ruled that the laws she invoked did not allow suits for such emotional harm. "More education, getting the word out there, showing that you know these cases are real and that people need to be given the same access to housing regardless of disability," she said. As in the cases discussed in this section, foreseeability or knowledge of harm is a key feature of this method of proof. Waisome v. Port Auth. However, plaintiffs alleging intentional discrimination under civil rights statutes need not demonstrate the existence of a similarly situated entity who or which was treated better than the plaintiff in order to prevail. Pac. Courts have developed a number of analytical frameworks for assessing intent claims. [13] See, e.g., N.C. State Conf. Emotional Distress Damages After Latest Supreme Court https://labor.hawaii.gov. NLR does not answer legal questions nor will we refer you to an attorney or other professional if you request such information from us. The Meeker Housing Authority and the Town of Meeker together settled with the plaintiffs for $1 million. In general, the bases for discrimination can be categorized as follows: Despite the fact that racial discrimination is illegal, it unfortunately still occurs. 1990). 2d 799, 806 (N.D. Ohio 2003) (citations, identifiable similarly situated individuals, approach. What are some of the consequences of housing discrimination? at 339 n.20. Webcan you play the radio in your business ranking nfl qb arm strength all timeemotional harm in housing discrimination cases. Direct evidence. Breaking the Link New Developments on U.S. The Department of Education's Office for Civil Rights is also available to provide assistance about the use of race in the educational context. The phrase pattern or practice can be used to describe a systemic violation of Title VI, regardless of the method of proof employed. In addition, impact evidence most often involves the presentation of statistical evidence. Discrimination in housing has numerous consequences. The court determined that, in the absence of the other Arlington Heights factors raised at the motion to dismiss stage, foreseeable impact alone is insufficient to demonstrate intent. White House Requires Removal of TikTok App from FDA Withdraws Proposed Rule on General Principles for Food Standards New FAQs Dramatically Expand Scope of California Labor Contractor Today is the Day Dont Miss the Employer Deadline to Report to OSHA, PTO Seeks Comments on Role of Artificial Intelligence in Inventorship. See methods of proof discussed in Sections B.2 and B.3. Shores Props., 730 F.3d at 1158-59 (explaining that a plaintiff need not rely on the McDonnell-Douglas approach to intentional discrimination but may instead produce circumstantial evidence of intentional discrimination using the Arlington Heights method). Commn, 463 U.S. 582, 60708 (1983); Alexander v. Choate, 469 U.S. 287, 29293 (1985). It can be subtle, friendly, and difficult to pin down. Moreover, Title VIs broad nondiscrimination mandate means that investigating agencies generally should take an inclusive approach to determining legally sufficient harms. This discretion is limited by two crucial elements: the egregiousness of the Respondents behavior and the effect of that behavior on the Complainant. Shores Props., 730 F.3d at 1159. 2012). The law certainly stands as a bold and optimistic proclamation. For his son, it was the reason to get out of bed every day when his depression kept him from living his life each day. Hosp. Thomas v. Washington Cty. Thus, in general, enhanced emotional distress damages can be recoveredand kept on appealwhen medical evidence and/or testimony is present, as opposed to having testimony only from the employee and their friends and family. And the Sheehan court explained why: because such a requirement would cripple enforcement of the discrimination laws. Sheehan, 173 F.3d at 1044. [1] Unlike when seeking judicial enforcement, private parties may file administrative complaints under any theory of liability, including disparate impact. For example, some courts have looked to whether the disparity is statistically significant. Kirtok (808-586-8844) im kwalok non kim kajin ta eo kwo melele im kenono kake. L. J. Even if you are 80 years old and require the regular assistance of someone nearby, a landlord has no legal ground to refuse your tenancy if you have excellent credit history and references. A method of proofor analytical frameworkis an established way of organizing the evidence in an investigation or lawsuit in order to show why that evidence amounts to intentional discrimination. Emotional harm in housing discrimination cases Courts also find that emotional distress damages are available under the Fair Credit Reporting Act, although courts are divided as to whether a physical manifestation of the distress is required. Necesita ayuda en otro idioma? Even without a direct admission or express policy, a plaintiff may prove intentional discrimination with other forms of direct evidence demonstrating that the decisionmakers placed substantial negative reliance on an illegitimate criterion in reaching their decision. Price Waterhouse v. Hopkins, 490 U.S. 228, 277 (1989) (OConnor, J., concurring); [9] Venters v. City of Delphi, 123 F.3d 956, 972 (7th Cir. "I don't like bullies and I stand up to bullies.". The Court has also held that strict scrutiny does not automatically invalidate the use of race; race may be used when the government has a compelling interest supporting its use, and that use is narrowly tailored to support the stated compelling interest. Hawaii Civil Rights Commission Decides Fair Housing Case. Matou te fesosoani e ave atu fua se faaliliu upu mo oe. Discrimination in housing is defined as any type of discrimination that occurs when a person attempts to purchase, rent, or lease a home. Many laws that prohibit employment discrimination, such as Title VII of the 1964 Civil Rights Act and the Americans with Disabilities Act (ADA), permit employees to recover money damages for the pain and suffering caused by their employers discrimination against them. On the other hand, remarks by non-decisionmakers or remarks unrelated to the decision making process itself are not direct evidence of discrimination. Standard v. A.B.E.L. And since socioeconomic hardship disproportionately affects people with protected characteristics, these price hikes automatically discriminate against them. As we have seen, housing discrimination comes in many forms, and often happens on multiple bases simultaneously. Ill. 1995), affd, 87 F.3d 916 (7th Cir. / CBS Colorado. The ABCs Of Emotional Distress Damages In Employment Mandatory Arbitration Agreements Remain Valid in California, Antitrust Practitioners Expect Activity With Climate Issues. Plaintiffs, As mentioned previously, certain procedural, the school failed to provide a legitimate, C. Other Issues Affecting Title VI Cases Involving Possible, As previously noted, the term pattern or, For Title VI, that kind of widespread or broad, As previously stated, statistics typically are used to help establish that a pattern of, 766 F.2d 917, 929 (6th Cir. The burden-shifting framework may nevertheless serve as a useful paradigm for organizing and analyzing the evidence. Teamsters, 431 U.S. at 360 & n.46. Shores Props., 730 F.3d at 1158 n.21; see also Gallagher v. Magner, 619 F.3d 823, 833 (8th Cir. 2012) (Title IX, like the [Rehabilitation Act] was modeled after Title VI, and the text of all three acts [is] virtually identical .); Darensburg v. Metro. For example, were a written test used to determine eligibility for a federally funded benefit or program, and the test resulted in a much higher percentage of minorities than non-minorities being determined ineligible for the benefit or access to the program, that might present a case of systemic discrimination. This implies that proving the existence of discriminatory behavior against a protected class will be a difficult task. Dist., 665 F.3d 524, 548 (3d Cir. [7] The McDonnell- Douglas framework refers to McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). Rarely is the basis for the amount of the court's award satisfacto rily explained in UDAP statutes (state statutes of general applicability prohibiting unfair or deceptive practices) allow for emotional distress damages, except for the few statutes that explicitly exclude such recovery. Croson Co., 488 U.S. 469, 493 (1989), and Adarand Constructors, Inc., v. Pena, 515 U.S. 200, 226 (1995), established that any intentional use of race, whether for malicious or benign motives, is subject to the most careful judicial scrutiny. The Supreme Court has held that strict judicial scrutiny applies to a governmental entitys intentional use of race, a standard that applies through Title VI to any recipient of Title VI funds. The responsibility of taking care of a pet alone has given new meaning to his life. Indeed, a series of discrete episodes negatively affecting minorities can raise a plausible inference of discriminatory impact. You can file a Fair Housing complaint or a complaint with the US Department of Housing and Urban Development (HUD) if you believe you have been a victim of this type of discrimination. 2016). Waterhouse v. Hopkins, 490 U.S. 228, 277 (1989) (OConnor, J., By way of illustration, in Wilson v. Susquehanna Township Police Dept, 55 F.3d 126 (3d Cir. If, however, the school did provide a legitimate, nondiscriminatory reason for the different sanction, the Departments would probe further to determine whether the reason given for the enhanced sanction was an accurate statement of the reasons for different treatment of the two students, or constituted a pretext for racial discrimination. The Hawaii Civil Rights Commission is responsible for enforcing state civil rights laws that prohibit discrimination in employment, housing, public accommodations, and state-funded services. Tawag sa (808-586-8844) aron magpahibalo kung unsa ang imong sinulti-han. Sch. Direct evidence often involves a statement from a decision-maker that expresses a discriminatory motive. However, courts have recognized the standard in cases involving other forms of discriminatory conduct. The Supreme Court Grants Petition to Decide Constitutionality of CFPB Understanding Your Law Firms Value Proposition, Spike in Migrants Crossing U.S.-Canada Border Raising Concerns, Bill to Amend the Gramm-Leach-Bliley Act Introduced to Congress, Energy & Sustainability Washington Update March 2023. See NCLCs Fair Debt Collection 11.15.3.4. [20] Statistical evidence can sometimes serve by itself to establish a prima facie case in the pattern or practice context, in lieu of comparative evidence pertaining to each class member. The Final Decision and Order in William D. Hoshijo, Executive Director, on behalf of Kiona E. Boyd v. Jeffrey David Primack, Dkt. 2006)(same); Tsombanidis v. W. Haven Fire Dep't, 352 F.3d 565, 579-80 (2d Cir. This approach is closely related to the Arlington Heights framework. 2d 822, 902 (D. Ariz. 2013) (awarding injunctive relief to Title VI plaintiffs and finding that plaintiffs demonstrated racially disparate results and additional indicia of discriminatory intent) (citing Feeney, 442 U.S. at 272); see also Arlington Heights, 429 U.S. at 26466; Comm. The dissenting opinion by the three liberal justices argued that contract law would in fact allow for emotional distress damages in cases involving discrimination, and it was this more specific form of notice that should be determinative. Housing Discrimination: U.S. Supreme Court Cases The most obvious form of religion-based discrimination is when a landlord informs prospective tenants that a specific apartment is unavailable because the landlord does not want to rent to people of a particular religion. Wolf says some property owners do not understand the laws protecting these tenants or ignore these policies because they think residents will not have the resources to hire an attorney. ; and Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. at 339 n.20; Lujan v. Franklin Cty. Bd., 915 F.2d 922, 926 (4th Cir. In addition, in Arlington Heights, the selection of a similarly situated comparator group is a key feature of cases where plaintiffs proffer impact evidence. This is a research file with cases from a variety of sources . N.C. State Conf. Maquinas Vending tradicionales de snacks, bebidas, golosinas, alimentos o lo que tu desees. Similarly, in Hassan, an Equal Protection Clause case involving an express religious classification, the Third Circuit held that the NYPD's blanket monitoring of the Muslim community after the September 11 attacks failed strict scrutiny because the surveillance program was not narrowly tailored. As previously stated, statistics typically are used to help establish that a pattern of discrimination based on race, color, or national origin was the recipients standard operating procedure. Teamsters, 431 U.S. at 336; Hazelwood, 433 U.S. at 307. Importantly, the analyses under these civil rights laws are not always the same, but this discussion identifies principles that are applicable to Title VI. Feb. 23, 2015) (Title VI case citing Pac. Apr. In some cases, people of color are outright denied a lease or mortgage because of their skin color, while in others, they are steered towards specific neighborhoods known for high crime rates, poorer access to schools, or other negative characteristics. While the Court acknowledged that there are many exceptions to this usual rule that allow for emotional distress damages in contract cases, the majority of the six conservative justices found this to be beside the point. Other forms of direct evidence of intent. Conversely, in certain cases "a plaintiff's statistucal evidence alone might constitute a prima facia case." 2003. Through this testimony, the jury can learn about how the employee has changed and been impacted since the employers discrimination, harassment, or retaliation occurred. Web2003 Emotional Harm in Housing Discrimination Cases: A New Look at a Lingering Problem Victor M. Goode City University School of Law Conrad A. Johnson Colombia University School of Law Follow this and additional works at: https://ir.lawnet.fordham.edu/ulj Part of the Housing Law Commons In International Brotherhood of Teamsters v. United States, 431 U.S. 324 (1977), a case brought under the pattern or practice provision of Title VII, the Court stated that statistics showing racial or ethnic imbalance are probative because such imbalance is often a telltale sign of purposeful discrimination. Id. Cummings directly controls the availability of emotional distress damages under four federal discrimination statutesthe only federal discrimination statutes whose authority is based on the Spending Clause: Congressional authority for other federal discrimination statutes, such as the Equal Credit Opportunity Act (ECOA), the Fair Housing Act (FHA), and 42 U.S.C. Home at 214. See, e.g., Blunt v. Lower Merion School District, 767 F.3d 247, 27173 (3d Cir. The example below, from joint DOJ and Department of Education guidance, illustrates how the McDonnell-Douglas framework would inform an administrative investigation. Good News for American Businesses: H1-B Denial Rates Plummet Under USCIS Extends Comment Period for Proposed Fee Increases, OFCCP Rescinds Trump-Era Religious Exemption Rule. Even benign motivations for racial classifications are presumptively invalid and trigger strict scrutiny in Equal Protection Clause and Title VI cases. 1984)). AG Clamps Down on Local Solar and Battery Storage Moratoria. Recent CFPB Actions Focus on Protecting Military Families, New and Updated Guidance on the Scope of the UK Plastic Packaging Tax. Agencies should consider using this method for investigations involving the selection of individuals, such as for program participation, benefits, or services, particularly where the recipient provides a nondiscriminatory explanation for its decision. Words With Friends, Part 1: Insurance Requirements and Contracts, Legislator Proposes To Expand CFL To Encompass "Commercial CERCLA PFAS Scope May Broaden To Many More PFAS, AI Avatar App is the Latest Target of BIPA Class Action Litigation. 1994); accord, Pitre v. Western Elec. Compensatory Damages in Federal Fair Housing Cases 42.104(b)(1)(iv) (emphasis added). Department of Labor and Industrial Relations "That those individuals still are disabled and we have to treat them with the respect and dignity that they deserve.". Gender-based housing discrimination victims may have more difficulty finding suitable housing, which can lead to financial insecurity and devastating health consequences. Hawaii Civil Rights Commission Decides FAIR Housing CASE, $95,000 Awarded in Gender Identity Discrimination Case. Even in the limited circumstance when drawing racial distinctions is permissible to further [an important or] compelling state interest, [the recipient] is still constrained in how it may pursue that end. Grutter, 539 U.S. at 333 (quoting Shaw v. Hunt, 517 U.S. 899, 908 (1996)). Xerox Litig., 850 F. Supp. When discrimination is discovered, HUD may impose civil penalties on violators and compensate victims. 1996). Nevertheless the McDonnell-Douglas framework may be useful for complaint investigations, particularly where the investigation uncovers evidence of similarly situated comparators who were treated differently or better. It can take many forms and is common when people from various vulnerable populations are looking for a place to live. However, statistical evidence, while extremely beneficial, is not a necessity in impact cases. It will also give them a level of security they have never experienced when it comes to housing. Hawaii Civil Rights Commission Decides Fair Housing Case A plaintiff in a pattern or practice case can prove that discrimination was the defendants standard operating procedure by, among other things, presenting statistical evidence of similarly situated individuals not in the protected class who were treated better than those in the protected class. Your experience on this site will be improved by allowing cookies. Posted on November 21, 2021 emotional harm in housing discrimination cases. 1994); accord Troupe v. May Dept Stores Co., 20 F.3d 734, 736 (7th Cir. Accordingly, Assn, 43 F.3d 265, 276 (6th Cir. Ogletree, Deakins, Nash, Smoak & Stewart, P.C. Discrimination of this kind is not only unjust in principle, but it often forces families to relocate to a less desirable neighborhood, sacrifice school access, or pay higher costs to protect their children from the dangers of lower-quality housing options. at 130 (citations and quotations omitted). Awaganyo ti (808-586-8844) tapno ibagayo kadakami no ania ti pagsasao nga ar-aramatenyo. The district court missed the forest in carefully surveying the many trees. Id. Although this is the case, it is often very difficult to determine an appropriate amount of such damages since Pennsylvania has not yet established a system by which to determine this. The Commission also ordered Jeffrey Primack to immediately cease and desist unlawful discriminatory practices, develop and implement a written anti-discrimination in real property transactions policy, and attend a fair housing training session. Doe v. Lower Merion Sch. 1681 et seq. For example, a statement of an official involved in the decision stating that an ostensibly race-neutral action was taken in order to limit minority individuals eligibility for a federally funded benefit or program is direct evidence of race-based intent. [4] See Grutter v. Bollinger, 539 U.S. 306, 34344 (2003) (citing Regents of Univ. 01-702 (FLW), 2006 WL 1097498 at *36 (D.N.J. (2003). at 533. [22] The Hassan court stated: We have learned from experience that it is often where the asserted interest appears most compelling that we must be most vigilant in protecting constitutional rights. 1991). of Educ. In other instances, a recipient explicitly conditions the receipt of benefits or services on the race, color, or national origin of the beneficiary, or explicitly directs action be taken based on race, color, or national origin. What are the characteristics of housing discrimination? Finally, it is important for agencies to remember that even if a recipient is found to have engaged in the intentional consideration of race, color, or national origin, this is not the end of the inquiry. Nevertheless, housing discrimination remains persistent and Title VIII is a mere stopgap measure for a social issue that seems intractable. The box below cross-references the major types of evidence with the related methods of proof discussed in this section. Copyright, National Consumer Law Center, Inc., All rights reserved. Dist. Appx 247 (4th Cir. [15] In a subsequent proceeding, the court granted summary judgment for the defendants on the issue of intentional discrimination under Title VI by noting that assuming, arguendo, that Plaintiffs are correct that [t]he disparate impact of [issuing the permit to the defendant] was clearly [foreseeable] to [the defendants], Pls. Opp. at 71, such a foreseeable impact is of no aid to Plaintiffs at this juncture because it, alone, is insufficient to establish a constitutional violation. S. Camden Citizens in Action v. N.J. Dept of Envtl. See Texas Dept of Cmty. An official website of the United States government. Title VIs plain language supports this approach. National Law Review, Volume X, Number 212, Public Services, Infrastructure, Transportation. Some have argued that this has been primarily due to the deficiencies in the law itself. 2008); Fitzgerald v. Action, Inc., 521 F.3d 867, 877 (8th Cir. Federal investigating agencies are encouraged to review applicable guidance documents and case law, and to consult their legal counsel or the Civil Rights Division for assistance applying applicable legal principles to specific situations. [22] Korematsu v. United States, 324 U.S. 885 (1944). These factors are non-exhaustive. Pac. Zuckerman Law represents whistleblowers worldwide inDodd-Frank SEC whistleblower rewardsclaims and represent whistleblowers nationwide inSarbanes-Oxley retaliation claimsand other whistleblower retaliation claims litigated before the US Department of Labor. The majority and minority opinions in Cummings instead provide a handy shortcut for a consumer attorney seeking to develop bases to recover emotional distress damages in breach of contract or warranty cases. 28, 2022), a deaf and legally blind individual was denied a sign language translator when receiving physical therapy services. Splitting 6 to 3, the court ruled that facilities receiving federal money cannot be sued under four federal laws for discrimination that causes emotional distress. 2013) (rejecting the Citys suggestion that law-abiding members of some racial groups have a greater tendency to appear suspicious than members of other racial groups, ruling that a stop and frisk program was racially discriminatory).
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