Justia Civil Rights Opinion Summaries

The Washington State Attorney General filed a lawsuit against the city of Sunnyside and several of its officials, alleging that the city's crime-free rental housing program (CFRHP) was being used to evict tenants without due process and that these evictions disproportionately impacted Latinx renters, women-headed households, and families with minor children. The city argued that the Attorney General lacked the authority to bring this suit, as the scope of the Attorney General's authority under RCW 43.10.030(1) limits their ability to act to matters that impact more people than those affected by the CFRHP. The trial court granted summary judgment in favor of the defendants.On appeal, the Supreme Court of Washington reversed and remanded the case. The court held that the Attorney General did have the authority to bring the suit, as the case involved matters of public concern in which the state had an interest. The court also found that there were genuine disputes of material fact regarding whether the city's enforcement of the CFRHP had a disparate impact on protected classes, and whether the individual respondents were entitled to qualified immunity. However, the court affirmed the trial court's grant of summary judgment on the Attorney General's claims under the Residential Landlord-Tenant Act, finding that the respondents were not landlords and therefore the Act did not apply to them. View "State v. City of Sunnyside" on Justia Law

The United States Court of Appeals for the Eighth Circuit affirmed a district court's grant of summary judgment, based on qualified immunity, in favor of government attorneys Michael Spindler-Krage and Thomas Canan. The plaintiff, Michael Davitt, had brought a 42 U.S.C. § 1983 action against Spindler-Krage and Canan, alleging they violated his Fourth and Fourteenth Amendment rights when they advised police that Davitt could be removed from his hotel room without eviction proceedings.During the COVID-19 pandemic, Olmsted County, Minnesota, arranged temporary, non-communal housing for elderly and vulnerable homeless individuals. Davitt, who was 69 years old and homeless, was moved into a Super 8 hotel room. When the county stopped paying for his room, Davitt refused to leave, citing a Minnesota governor's executive order temporarily prohibiting evictions. Spindler-Krage and Canan, after reviewing the relevant state law, the executive order, and the Agreement for Hotel Guests, advised the police that Davitt was a hotel guest, not a tenant protected by the executive order.In granting Spindler-Krage and Canan summary judgment based on qualified immunity, the district court found that no case law, statute, or other legal authority clearly established that Davitt was a tenant with a constitutionally protected right to his hotel room. The court also found that the advice provided to the police was objectively reasonable. The Court of Appeals agreed, ruling that Spindler-Krage and Canan did not violate Davitt’s clearly established rights and were thus entitled to qualified immunity. View "Davitt v. Krage" on Justia Law

The Supreme Court of New Jersey delivered an opinion concerning an appeal by condominium owners who claimed they were discriminated against because of their need for an emotional support animal (ESA) that exceeded the weight limit set by the condominium association's pet policy. The owners argued that their ESA, a 63-pound dog, was necessary for one of the owners who had been diagnosed with several mental health conditions. The court considered whether the trial court correctly dismissed the disability discrimination claims under New Jersey's Law Against Discrimination (LAD) and how requests of this type should be evaluated under the LAD.The court held that individuals seeking an accommodation must show they have a disability under the LAD and demonstrate that the requested accommodation may be necessary to afford them an "equal opportunity to use and enjoy a dwelling." The housing provider then has the burden to prove that the requested accommodation is unreasonable. Both sides should engage in good-faith, interactive dialogue in this process. If the parties cannot resolve the request, courts may be called on to balance the need for, and benefits of, the requested accommodation against cost and administrative burdens it presents. With this framework, the court found that the owners' claims should not have been dismissed and remanded the matter. View "Players Place II Condominium Association, Inc. v. K.P. and B.F." on Justia Law

In this case from the Supreme Court of the State of Colorado, petitioner Claire E. Miller and respondent Jesse A. Amos were involved in a dispute related to eviction proceedings. Miller was a tenant who lived in a home owned and occupied by Amos. Their arrangement was an oral tenancy agreement where Miller agreed to provide pet care and light housekeeping services instead of paying rent. After six months, Amos served Miller with a notice to quit, alleging breach of their oral agreement. Miller refused to move out, and Amos filed a forcible entry and detainer (FED) complaint seeking eviction. Miller contended that her eviction was due to her refusal to engage in sexual acts with Amos, which she stated was a form of sex discrimination and retaliation under the Colorado Fair Housing Act (CFHA).The county court ruled in favor of Amos, stating that a landlord can serve a notice to quit for “no reason or any reason,” dismissing the CFHA violation claim as an affirmative defense for eviction. The district court affirmed this decision.On appeal, the Supreme Court of the State of Colorado reversed the lower court's ruling. The court held that a tenant can assert a landlord’s alleged violation of the CFHA as an affirmative defense to an FED eviction. The court noted that the purpose of the CFHA is to prevent discriminatory practices, and therefore, a tenant must be able to use it as a shield against a discriminatory eviction. The court also emphasized that a tenant's right to due process must be preserved even in eviction proceedings, which are intended to be expedited. This decision allows tenants in Colorado to assert discrimination or retaliation under the CFHA as a defense in eviction cases. View "Miller v. Amos" on Justia Law

A plaintiff, Robert Trebelhorn, suffered a serious knee injury at his apartment complex when a section of an elevated walkway collapsed due to deterioration. The defendants, Prime Wimbledon SPE, LLC, and Prime Administration, LLC, who owned and managed the apartment complex, were aware of the deteriorated condition of the walkway but chose not to repair it. Trebelhorn sued the defendants for negligence and violation of Oregon's Residential Landlord-Tenant Act and won. The jury awarded him just under $300,000 in damages and also imposed punitive damages of $10 million against each defendant. On post-verdict review, the trial court concluded that although the evidence supported some amount of punitive damages, the amount of $10 million would violate the defendants' due process rights. The trial court reduced the punitive damages to just under $2.7 million against each defendant. On cross-appeals, the Court of Appeals agreed with the trial court and affirmed. The Supreme Court of the State of Oregon also agreed with the trial court that $10 million in punitive damages would violate the defendants' due process rights and affirmed the judgment of the trial court and the decision of the Court of Appeals. View "Trebelhorn v. Prime Wimbledon SPE, LLC" on Justia Law

In this case, residents of the Waples Mobile Home Park in Fairfax, Virginia, challenged the park's policy that required all adult tenants to provide proof of their legal status in the United States in order to renew their leases. The plaintiffs, four Latino families, argued that this policy violated the Fair Housing Act (FHA) because it disproportionately ousted Latinos from the park. The district court initially granted summary judgment in favor of the park, reasoning that the policy was necessary to avoid criminal liability under a federal statute prohibiting the harboring of undocumented immigrants.However, the United States Court of Appeals for the Fourth Circuit reversed the district court's judgment. The court of appeals found that the district court had misunderstood the federal anti-harboring statute. The court of appeals noted that the statute requires more than simply entering into a lease agreement with an undocumented immigrant to be in violation. Rather, a person must knowingly or recklessly conceal, harbor, or shield undocumented immigrants from detection. The court of appeals concluded that the park's policy of verifying tenants' legal status did not serve the park's stated interest of avoiding liability under the anti-harboring statute. Consequently, the park had not met its burden at the second step of the three-step burden-shifting framework established for disparate-impact claims under the FHA. As such, the court of appeals reversed the grant of summary judgment for the park and remanded the case to the district court for further proceedings. View "Reyes v. Waples Mobile Home Park Limited Partnership" on Justia Law

In a case brought before the United States Court of Appeals for the Fourth Circuit, residents of the Waples Mobile Home Park in Fairfax, Virginia, challenged the Park's policy requiring all adult tenants to provide proof of their legal status in the United States in order to renew their leases. The plaintiffs, noncitizen Latino families, argued that this policy disproportionately ousted Latinos from the Park and therefore violated the Fair Housing Act (FHA). The district court initially granted summary judgment in favor of the Park, reasoning that the policy was necessary to avoid criminal liability under a federal statute prohibiting the harboring of undocumented immigrants.On appeal, the Fourth Circuit reversed the district court's decision. The court determined that the anti-harboring statute did not plausibly put the Park at risk for prosecution simply for leasing to families with undocumented immigrants. Furthermore, the court found that the Park's policy did not serve a valid interest in any realistic way to avoid liability under the anti-harboring statute. Therefore, the Park did not meet its burden at the second step of the three-step burden-shifting framework established for disparate-impact claims in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc. Given these findings, the Court of Appeals did not need to reach the third step to determine whether a less discriminatory alternative was available. As such, the court reversed the grant of summary judgment for the Park and remanded the case to the district court for further proceedings. View "Reyes v. Waples Mobile Home Park Limited Partnership" on Justia Law

In this case, Nagla Abdelhalim, an Egyptian immigrant and a Muslim woman, filed suit against her neighbors Aaron and Dinara Lewis and Andrew and Roxana McDevitt, alleging that they violated the Fair Housing Act by engaging in a year-long campaign of harassment against her in an attempt to drive her out of the neighborhood because of her race, national origin, and religion. The dispute began when Abdelhalim started a short-term rental business, renting out her basement on platforms such as Airbnb, which violated a local ordinance at the time and was disapproved by her neighbors. The United States District Court for the Eastern District of Virginia granted summary judgment to the defendants, concluding that Abdelhalim had not produced evidence of intentional discrimination based on a protected ground.On appeal, the United States Court of Appeals for the Fourth Circuit considered only whether the district court erred in granting the defendants' motions for attorneys’ fees. The Fourth Circuit ruled that the district court had applied the wrong legal standard and thus abused its discretion in granting attorneys’ fees to the defendants. The court noted that while a plaintiff’s failure to prevail is a factor to consider, it alone cannot be the basis for concluding that a claim was without foundation. The court found that Abdelhalim had provided sufficient evidence to support her belief that the defendants intended to discriminate against her based on her race, religion, or national origin. Thus, her claims were not without foundation, and the award of attorneys' fees to the defendants was vacated. View "Abdelhalim v. Lewis" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the district court's ruling in this eminent domain case between Tenants and City involving the requirement that a condemning authority provide certain relocation benefits and assistance to those displaced by the government's exercise of eminent domain, holding that the district court lacked subject matter jurisdiction over Tenants' petition to recover relocation expenses.Specifically, the Supreme Court held (1) the district court lacked subject matter jurisdiction over Tenants' petition because the Kansas Eminent Domain Procedure Act (EDPA), Kan. Stat. Ann. 26-501 et seq., neither provides a private right of action to recover relocation benefits nor authorizes judicial review of relocation-benefit determinations in eminent-domain appeals; (2) while the Kansas Relocation Assistance for Persons Displayed by Acquisition of Real Property Act (KRA), Kan. Stat. Ann. 58-3501 et seq., does provide an administrative remedy to vindicate the statutory right to relocation benefits, Tenants' failure to exhaust this administrative remedy deprived the district court of subject matter jurisdiction under the KRA; and (3) while Kan. Stat. Ann. 60-2101(d) authorizes appeals to the district court from certain final judgments and orders of a political subdivision, the statute did not apply in this case. View "Kan. Fire & Safety Equipment v. City of Topeka" on Justia Law

After the Supreme Court held in HUD v. Rucker, 535 U.S. 125 (2002), that a public housing authority may enforce a term in a tenant’s lease allowing eviction if a member of the household or guest commits a crime (even without the tenant’s knowledge), some cities enacted ordinances extending that approach to private leases. Granite City, Illinois, required private landlords to evict tenants not as a condition of receiving a subsidy but as a matter of regulatory compulsion. Plaintiffs permitted their adult daughter to stay in their leased home occasionally, and one night they welcomed their daughter and her boyfriend into their house briefly. After they left, they were arrested for stealing a van. The City served a “Notice of Violation.” A hearing officer directed Plaintiffs’ landlord to begin eviction proceedings. The landlord dragged his feet long enough for them to file suit under 42 U.S.C. Section 1983. A district court entered a temporary restraining order, which it later converted to a preliminary injunction. In January 2022, Plaintiffs gave up their lease voluntarily and moved out of Granite City.   The Seventh Circuit vacated the district court’s judgment and remanded with instructions to dismiss for lack of a justiciable controversy. Plaintiffs contend that if they prevail on the merits, they will be entitled to nominal damages. The court explained Plaintiffs’ potential problem is that their complaint did not allege a “completed” violation of their rights, so they have failed to identify a concrete injury that could be redressed by nominal damages. View "Deborah Brumit v Granite City, Illinois" on Justia Law