Matter of State Division of Human Rights v. St. Elizabeth’s Hospital, 41 N.Y.2d 865 (1977)
Unlawful discrimination is often subtle, and administrative agencies can draw inferences of discrimination from circumstantial evidence, even if others might require stronger proof.
Summary
This case concerns a finding of unlawful housing discrimination by the State Division of Human Rights against a landlord. The agency credited testimony indicating the landlord delayed Black applicants and sought white tenants to maintain a building free of Black residents. Although one apartment was eventually rented to a Black applicant, the agency deemed this a deceptive maneuver to mask discriminatory practices. The Court of Appeals affirmed the agency’s decision, holding that the inference-making function rests exclusively with the administrative agency at the fact-finding level and that substantial evidence supported the finding of discrimination, even if circumstantial.
Facts
Mrs. Trommer of the Urban League of Westchester County testified that the building superintendent’s wife (from whom he was now separated) explained in detail the practice of holding off Black applicants for two vacant apartments. The superintendent’s wife also indicated the landlord’s preference for white prospects and the intention to keep the building free of Black tenants. One of the apartments was eventually rented to an early Black applicant who had previously been delayed. The landlord corporation’s principal and the superintendent’s wife were not called as witnesses.
Procedural History
The State Division of Human Rights found unlawful discrimination. The lower courts affirmed this determination. The case then went to the New York Court of Appeals.
Issue(s)
Whether there was substantial evidence to support the administrative agency’s determination of unlawful housing discrimination, allowing it to draw inferences from circumstantial evidence.
Holding
Yes, because unlawful discrimination is often practiced subtly, and the inference-making function belongs exclusively to the administrative agency at the fact-finding level when supported by substantial evidence.
Court’s Reasoning
The Court of Appeals emphasized that unlawful discrimination is generally practiced subtly. It noted the agency credited Mrs. Trommer’s testimony regarding the landlord’s discriminatory practices. The Court highlighted the absence of the superintendent’s wife and the landlord’s principal as witnesses to contradict Mrs. Trommer’s testimony. The renting of one apartment to a Black tenant was interpreted as a deceptive tactic to conceal discriminatory intent once the investigation commenced. The Court underscored the administrative agency’s exclusive role in making inferences at the fact-finding level, citing Matter of Pell v Board of Educ., 34 NY2d 222, 230 and Matter of Holland v Edwards, 307 NY 38, 44. The court stated, “That others would require stronger evidence to reach the ultimate factual inferences is not relevant. The inference-making function, as it is exercised at the evidentiary or fact-finding level, is exclusively that of the administrative agency.” The court affirmed that there was “more than ample evidence” to support the agency’s inferences. Therefore, the court upheld the agency’s determination that the landlord engaged in unlawful discriminatory practices.