Bank of Am. Corp. v. City of Miami, 137 S. Ct. 1296

Background

The City of Miami sued Bank of America and Wells Fargo under the Fair Housing Act (FHA), alleging the banks engaged in racially discriminatory lending (steeper terms, predatory features, refusal to modify/refinance) targeted at African‑American and Latino borrowers.
The City alleged those practices produced higher default and foreclosure rates concentrated in minority neighborhoods, causing vacancies, depressed property values, reduced property‑tax revenue, and increased municipal service costs (police, fire, code enforcement, blight remediation).
District Court dismissed the complaints for (1) falling outside the FHA’s zone‑of‑interests (so the City was not an "aggrieved person") and (2) failing to plead sufficient proximate causation; statute‑of‑limitations issues also arose.
The Eleventh Circuit reversed, finding the City’s economic injuries were within the FHA’s zone‑of‑interests and that proximate cause could be shown because the City’s injuries were foreseeable results of the banks’ misconduct.
Supreme Court granted certiorari and held: (1) the City’s alleged financial injuries are at least "arguably within the zone of interests" protected by the FHA, so the City may sue as an "aggrieved person"; (2) foreseeability alone is insufficient to establish proximate cause under the FHA; the case is vacated and remanded for the lower courts to apply an appropriate proximate‑cause analysis.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Zone of interests: Does the FHA permit a municipality to sue for lost tax revenue and increased municipal costs caused by discriminatory lending?	Miami: Its economic harms (lost tax revenue, extra municipal expenses) flow from FHA violations and are analogous to injuries recognized in prior FHA cases.	Banks: The FHA’s "aggrieved person" language should be limited; municipalities’ budgetary harms are not the type of interests the FHA protects and would extend liability too far.	Held: The City’s alleged financial injuries are at least "arguably within the zone of interests" of the FHA, so the City may proceed as an "aggrieved person."
Proximate cause: Must plaintiff show more than foreseeability to recover damages under the FHA?	Miami: The City plausibly alleged that its losses were foreseeable consequences of the banks’ discriminatory practices.	Banks: The causal chain is too attenuated; allowing damages for such remote effects would be improper.	Held: Foreseeability alone is insufficient; proximate cause requires a sufficiently direct connection (some direct relation) between the prohibited conduct and the asserted injuries. Lower courts must define and apply the proximate‑cause boundaries under the FHA.
Standard for judicially implied causes of action under FHA (statutory standing): How to interpret "aggrieved person"?	Miami: The FHA’s text and precedent permit broad standing for parties similarly situated to prior successful plaintiffs.	Banks: The term should not automatically confer a cause of action to every Article III–injured party; common‑law zone‑of‑interests limits apply.	Held: Apply the Lexmark zone‑of‑interests framework; prior FHA precedents (Trafficante, Gladstone, Havens) and Congress’s reenactment support permitting the City’s claim as arguably within the FHA’s protected interests.
Remedy scope and administrative practicability: Should courts permit recovery for widespread, indirect economic harms from FHA violations?	Miami: Remedies for injuries flowing from discrimination are appropriate to vindicate FHA purposes.	Banks: Allowing recovery for diffuse economic harms risks massive, complex litigation and exceeds what Congress intended.	Held: Court endorses concern; proximate‑cause limits must prevent liability for overly remote harms. The precise boundary is left for lower courts to develop.

Key Cases Cited

Trafficante v. Metropolitan Life Ins. Co., 409 U.S. 205 (1972) (interpreting FHA standing broadly for those harmed by racial steering and segregation)
Gladstone, Realtors v. Village of Bellwood, 441 U.S. 91 (1979) (municipality may sue for reduced tax revenue and altered racial composition caused by discriminatory steering)
Havens Realty Corp. v. Coleman, 455 U.S. 363 (1982) (testers and informational injury recognized under FHA)
Lexmark Int’l, Inc. v. Static Control Components, Inc., 572 U.S. 118 (2014) (adopted zone‑of‑interests test to determine statutory causes of action)
Holmes v. Securities Investor Protection Corp., 503 U.S. 258 (1992) (proximate cause requires direct relation between injury and wrongful conduct)
Associated Gen. Contractors of Cal., Inc. v. Carpenters, 459 U.S. 519 (1983) (caution against liability for remote or indirect consequences; concern about massive litigation)
Anza v. Ideal Steel Supply Corp., 547 U.S. 451 (2006) (application of proximate‑cause/directness principles in statutory suits)
Hemi Group, LLC v. City of New York, 559 U.S. 1 (2010) (reluctance to extend damages beyond the first step in causal chain)
Meyer v. Holley, 537 U.S. 280 (2003) (FHA damages analogous to tort actions)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (Article III standing requirements)
Thompson v. North American Stainless, LP, 562 U.S. 170 (2011) (zone‑of‑interests limitation applies even where statutory language appears broad)