THE YAMACRAW FIGHT: A CIVIL RIGHTS CHALLENGE
Legal Memorandum opposing the Demolition of Yamacraw Village Public Housing
Attorneys from the National Housing Law Project, Georgia Legal Services Program, and The Lawyers’ Committee for Civil Rights Under Law submitted a legal memorandum to HUD and HAS on behalf of the YRC asserting that the proposed demolition by HAS violates the Fair Housing Act and key federal regulations.
FHA: Discriminatory Effect
96% Black
The overwhelming racial composition of the community facing eviction.
FHA: Segregation Risk
81% Refusal
Local landlords denying tenancies to voucher holders, proving bias.
Section 18 Violations
False Certification
HAS failed to disclose an existing disability discrimination Consent Order.
The Better Way Forward
RAD Blend
The alternative funding path guaranteeing 315 replacement units.
I. The FHA Case: Disproportionate Adverse Impact
The core legal argument is that the demolition’s impact falls disproportionately on legally protected groups. Yamacraw Village, historically a Black neighborhood, is now an island of deep affordability in a rapidly gentrifying Downtown Savannah. Removing these 98 families (who are 96% Black and 81% include children) eliminates a critical source of wealth and stability in a high-opportunity area.
Affected Families
98
Remaining occupied units.
Familial Impact
81.19%
Of Yamacraw households include minors.
Disability Barrier
“First Out” Policy
Disparately harms people with disabilities who require more time to move.
Visualizing the Economic and Racial Disparity
Income & Population Comparison (Yamacraw is a racial and economic outlier)
Affordable Housing Eligibility Need (Households below 50% AMI)
II. The FHA Case: Vouchers Guarantee Segregation
The plan relies on displaced tenants finding housing using Housing Choice Vouchers (HCVs). The brief argues this mechanism guarantees that Black, low-income families will be forced into existing, high-poverty, segregated neighborhoods far from Downtown jobs and resources.
The Landlord Barrier
An independent fair housing test found overwhelming source of income discrimination against voucher holders in the Yamacraw school district, making the voucher unusable for most.
Geospatial Segregation – A Forced Exodus
Illustration of the displacement from high-opportunity Downtown to segregated HCV cluster zones.
III. HAS Regulatory & Procedural Failures
The legal opposition asserts that HUD cannot approve the application because HAS failed to meet required Section 18 consultation and compliance standards.
Timeline of Procedural Violations
Dec 2024:
YRC Certified
Feb 2025:
Disability Consent Order Issued
Apr 2025:
HAS Board Approves Demolition (Violation)
Aug 2025:
RAB Consultation (Excludes YRC)
Oct 2025:
Legal Memo Filed
- Failure to Disclose Remedial Order: HAS falsely certified that it was not operating under any remedial agreements, despite an active February 25, 2025 Consent Order related to disability discrimination.
- Consultation Failure: HAS Board approved the demolition before completing required consultation with the Yamacraw Resident Council (YRC) and the Resident Advisory Board (RAB), a clear violation of 24 C.F.R. § 970.7(a)(13).
- Willful Neglect: HAS is accused of failing to maintain the property (after an initial HUD rejection in 2022) to create the obsolescence conditions it now uses to justify the demolition, violating the obligation to continue providing full housing services.
IV. The Less Discriminatory Alternative: RAD Blend
The opposition proposes a Section 18/RAD Blend as a solution that meets HAS’s stated goals while providing mandatory civil rights protections and maximizing long-term funding.
The Financial Imperative
A straight Section 18 demolition only yields 185 Tenant Protection Vouchers (TPVs) due to the high vacancy rate, resulting in a permanent loss of 130 unit subsidies.
The RAD Blend Alternative:
- Secures 315 Project-Based Vouchers (PBVs) (one-to-one replacement).
- Supports an estimated $100 Million in LIHTC financing.
- Guarantees long-term affordability through deed restriction.
YRC’s Enforceable Deal Terms
- Legally Enforceable Relocation Agreement with YRC.
- Guarantee 315 Deeply Affordable Units rebuilt on site (50-year deed restriction).
- Procure an Independent Mobility Counselor selected with YRC input.
- Right to Return for all former residents without re-screening (only Section 8 income-eligibility applies).
TAKE ACTION NOW: Demand the RAD Blend Alternative.
Contact HUD: James.A.Isaacs@hud.gov (Acting Director, SAC)
Contact HAS: Ehester@savannahpha.com (Executive Director, HAS)