By: Eve Hastings
Associate Editor, Vol. 26
Mapping Inequality is a website created through the collaboration of three teams at four universities including the University of Richmond, Virginia Tech, University of Maryland, and Johns Hopkins University. I was introduced to the website through my Property professor during the Fall 2020 semester as we learned about the racist history of redlining, predatory lending, and racially restrictive covenants that continue to have lingering consequences on the racial makeup of house ownership in the United States. The website includes interactive maps of various areas of the United States with the grades and descriptions from the now-defunct Home Owners’ Loan Corporation (HOLC) accompanying them. These descriptions were often racist and resulted in the systematic exclusion of people of color – specifically Black people – from getting mortgage financing or from moving into wealthy neighborhoods.
The HOLC grades were created with the use of data and evaluations compiled from local real estate professionals who would color code maps and label neighborhoods with the highest grade being “A” signaling minimal risk for mortgage lenders to “D” which were considered hazardous neighborhoods for lenders.These grades were accompanied by area descriptions, which typically included the neighborhood’s quality of housing, the recent history of sale and rent values, class of residents, and the racial and ethnic identity of residents. As the Mapping Inequality authors put it, “These maps and their accompanying documentation helped set the rules for nearly a century of real estate practice.”
HOLC assumed that the residency of African Americans and immigrants, as well as working-class whites, lowered the value of homes and the security of mortgages. This racist mindset was supported by Frederick Babcock, the central figure in early twentieth-century real estate appraisal standards and author of the Federal Housing Authority’s (FHA) Underwriting Manual.  According to Babcock’s FHA Underwriting Manual: “The infiltration of inharmonious racial groups . . . tend to lower the levels of land values and to lessen the desirability of residential areas.” The HOLC area descriptions are full of this type of racist language referencing what they deemed to be “undesirable” or “lower grade” populations. The introduction page of Mapping Inequality gives these examples:
The “infiltration of negroes” informed the grades of neighborhoods in Birmingham, Oakland, Charlotte, Youngstown, Indianapolis, Cleveland, Los Angeles, and Chicago; the “infiltration of Jews” or “infiltration of Jewish families” in Los Angeles, Binghamton, Kansas City, and Chicago; the “infiltration of Italians” in Akron, Chicago, Cleveland, and Kansas City. The “infiltration” of Polish, Hungarian, Czech, Greek, Mexican, Russian, Slavic, and Syrian families was cataloged in other cities, always lowering the grade of neighborhoods.
Importantly, these HOLC ratings were adopted by the FHA. Thus, the grades generated by the HOLC were a tool for systematically denying financing for buying a home to African Americans. This process, called redlining because of the literal red lines on the HOLC maps, made it difficult or impossible for people of color in certain areas to get mortgage financing and purchase a home. Redlining directed both public and private capital to white families and away from African American and immigrant families. Because homeownership is arguably the most significant means of intergenerational wealth building in the United States, redlining practices from decades ago have had long-term effects in creating and exacerbating existing wealth inequalities that we still see today.
While exploring the Mapping Inequality website for my Property class, I chose to look at Grand Rapids, MI. I’m from just north of Grand Rapids (Rockford, MI) but it was still really interesting to look at the maps and find landmarks I recognized. It was striking to see how the neighborhoods around them were classified and compare that to my knowledge of the area now. For example, I was able to find the street my husband’s family lives on (in area B15 if you’re following along on the website) and read the area description which matched pretty much what I thought it would since I know that it’s a predominantly white area today. However, reading words like “infiltration” with respect to people of color moving into the neighborhood and knowing that the government labeling of the street’s “desirability” was based on the racial makeup was hard to swallow. It also made me reflect on how that map from 1955 has certainly impacted who my husband’s neighbors were while he was growing up on that street decades later.
Although I studied race and racism in an academic context fairly extensively in college (my undergraduate major was in Afro-American and African studies) and even knew quite a bit about redlining and land contracts before taking Property law, I did not know much about racially restrictive covenants that can run with the land and continue to perpetuate harm, even after the formal racist policies were unenforceable. The Mapping Inequality website was a really helpful way to put things into perspective by making me look at places I am familiar with through the lens of redlining.
Reading these maps helped me to understand more concretely the impact of cases such as Parmalee v. Morris, where the Michigan Supreme Court upheld a racially restrictive covenant for property that was on a subdivision, thereby denying a Black purchaser the right to occupy his own land. Although this was eventually corrected in Shelley v. Kraemer, which made the types of covenants at issue in Parmalee unenforceable, the fact that we have so many cases in American jurisprudence, that, like Parmalee, are overtly racist but written under the guise of legal logic is frankly infuriating. The extent of damage that our federal government perpetuated (and arguably continues to do so) is overwhelming and these maps made it more concrete for me as a white person who has never experienced housing discrimination. One of the other things I got out of my Property class and the Mapping Inequality website is that it’s really hard to tease out the line between where the law is doing the work of racial discrimination in housing and where social norms are at work because they tend to be mutually reinforcing. It was the social norms in the 1950s that encouraged the passing of discriminatory policy and the existence of discriminatory policies that perpetuated social norms of discrimination far into the future.
My takeaway is that both the law and social norms can cause serious harm towards marginalized groups, so we cannot think about one to the complete exclusion of the other. I think one of the most important things that we can learn from this history is that just taking away one of these two, mutually reinforcing pieces, does not solve the problem of housing discrimination. After Shelley, racially restrictive covenants were unenforceable, but many areas of the country are still segregated, and people still hold discriminatory views against people of color. Changing the law did not immediately change social norms. In places like Ann Arbor, MI changing social norms have not gotten rid of all of the remnants of the discriminatory laws. For example, even today, a significant number of Ann Arbor suburbs and individual houses have racially-restrictive sections in their covenants which bar people of color from home ownership.  Although they are not enforceable after Shelley v. Kraemer, they are present in many closing documents because the removal process is long and expensive.
So, we’re left with the question, does the law have the power to change social norms? I think yes. Although the law can linger behind changing attitudes and norms at times, I think it can provide an invaluable form of protection for underrepresented groups from the tyranny of the majority. I hope, through activism, that our housing and property laws can begin to turn the corner and push us towards equality instead of posing a barrier to progress.
 Mapping Inequality: Redlining in New Deal America, https://dsl.richmond.edu/panorama/redlining/#loc=5/39.1/-94.58&text=intro (last visited Jan. 21, 2021).
 United States. Federal Housing Administration. Underwriting manual: underwriting analysis under title II, section 203 of the National housing act. Washington.
 Supra n.1
 Daniel Aaronson, Daniel Harley, Bhashkar Mazumder The Effects of the 1930s HOLC “Redlining” Maps, Federal Reserve Bank of Chicago, (Aug. 3, 2017), http://hdl.handle.net/10419/200568
 Parmalee v. Morris, 218 Mich. 625 (Mich. 1922).
 Shelley v. Kraemer, 68 S.Ct. 836 (1948).
 Parmalee, 218 Mich. 625
 Shelley, 68 S.Ct. at 847
 See, Shannon Stocking, U-M Research Raises Awareness of Racially Restrictive Covenants in Ann Arbor Housing, The Michigan Daily, (Jan. 26, 2021, 5:27 PM), https://www.michigandaily.com/section/ann-arbor/u-m-professors-reveal-racially-restrictive-covenants-ann-arbor-housing.