This study brought about the idea of environmental racism. Bullard made a correlation between the locations of toxic facilities and the race of the people in these communities. Dr. Bullard's correlations led America to its first environmental racism lawsuit, Bean v. Southwestern Waste Management, which "used civil rights law to challenge environmental discrimination." (Motavalli, 1998 p.1) Dr. Bullard brought into light the ideas and correlations which shape the debate today of environmental racism. (Motavalli, 1998).
There have been three types of development patterns, which seem to shape environmental racism. The first of these patterns is that homes are abandoned belonging to whites in areas of toxic plants due to the chemical intake. There is new room for minorities in toxic neighborhoods when the superior group leaves. The second type of pattern occurred in World War II, which consisted of lower income housing built in places where toxic waste sites already existed. An example of this is in Richmond, California where during World War II housing was built in the same area as a Chevron oil refinery for African Americans to live while working in the shipyards. The third type of pattern is the type which is most debated over. This pattern consists of toxic waste sites moving themselves into communities of color. (Austin, 1994) .
The term "environmental Racism" ceased to exist until 1982, when Reverend Ben Chavis realized that the waste sites in Warren County, NC were only there because the citizens in Warren county were both poor and black. Upon the realization of this concept, it was easy to see that environmental racism was another form of institutionalized discrimination against minorities. (Motavalli, 1998) However, there is also the argument that it is not any type of institutionalized discrimination but a variety of different factors including "income differentials, the lack of political power, and market outcomes reflecting land values.