# Inclusive Communities *Subject entry on* Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc. *(U.S. Supreme Court, 2015), as it bears on the Saint Paul disparate-impact record.* *Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc.*, 576 U.S. 519 (2015), is the United States Supreme Court decision holding that disparate-impact claims are cognizable under the [[Fair Housing Act]].[^1] The Court decided the case on June 25, 2015.[^2] The case enters the [[Minnesota]] record through Saint Paul. According to a validated project dossier, the government of Saint Paul withdrew a case from the Supreme Court in 2012, after the writ was dismissed by stipulation. The dossier describes it as the only case that had been granted certiorari on whether the disparate-impact standard applied in housing. It states that the question went unanswered until *Inclusive Communities*.[^3] A Ramsey County history row dates the decision three years and four months after that withdrawal.[^2] The project's at-issue catalogue sets the 2012 withdrawal beside the 2015 holding. Its federal anchor is a 2025 presidential action, *Restoring Equality of Opportunity and Meritocracy*, which the pair describes as addressing the holding.[^4][^5] The record shows the sequence of withdrawal and holding. It does not establish why the withdrawal was made. ## What The dossier states the question before the Court as "Are disparate impact claims cognizable under the Fair Housing Act?"[^3] The Court held that they are.[^1] Because the earlier Saint Paul case had been dismissed by stipulation, the dossier records the question as unanswered at the Supreme Court from 2012 until this decision.[^3] ## When - 2012: the government of Saint Paul withdraws the earlier case; the writ is dismissed by stipulation.[^3] - June 25, 2015: *Inclusive Communities* is decided.[^2] The Ramsey County history row places the decision three years and four months after the withdrawal.[^2] The at-issue pair gives the interval as three years.[^4] - 2025: the presidential action *Restoring Equality of Opportunity and Meritocracy* is issued. It is the federal anchor the at-issue pair cites.[^5] ## In the at-issue record Pair AI-Ramsey-012 is ranked 12 in Tier I, *The Doctrinal Spine*. It states that the 2012 withdrawal "did not kill the question," and characterizes the withdrawal as having "selected the vehicle" for the question's eventual answer.[^4] The pair lists two sources, a court source and a news source, on the domains supreme.justia.com and americanbanker.com. Of these, only the court report is among this entry's sources.[^4][^1] Set beside the anchor's title, the pair's note on the anchor states that the order addresses the holding the 2012 withdrawal made possible.[^4][^5] ## In the Minnesota record ### What The dossier further states that a joint congressional staff report found that the 2012 withdrawal was traded for the dismissal of two False Claims Act cases against the same city, valued at up to $200 million.[^3] The staff report itself is not among this entry's sources, so the finding is stated here as the dossier reports it.[^3] ## Notes [^1]: Supreme Court of the United States, *Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc.*, 576 U.S. 519 (2015) — establishes the holding that disparate-impact claims are cognizable under the Fair Housing Act. https://supreme.justia.com/cases/federal/us/576/519/ [^2]: Ramsey County complete history, companion table row HE-0225 (2026-09-02) — establishes the date of the decision as June 25, 2015, and places it three years and four months after the withdrawal. Record row; no URL in the pack. [^3]: Project dossier, *Warren E. Burger Apex Dossier* §V.d (validated, 2026-09-02) — records the stipulated dismissal of the writ, the question as stated, the 2015 holding, and the reported congressional staff finding. Dossier section; no URL in the pack. [^4]: At-issue pair AI-Ramsey-012, Ramsey package, *Tier I — The Doctrinal Spine* — sets the 2012 withdrawal beside the 2015 holding, states its sources, and cites the 2025 presidential action as its anchor. Record row; undated. [^5]: Executive Office of the President, *Restoring Equality of Opportunity and Meritocracy* (presidential action, 2025) — the federal anchor cited by pair AI-Ramsey-012. https://www.whitehouse.gov/presidential-actions/2025/04/restoring-equality-of-opportunity-and-meritocracy/