Donald Watkins, sued Property Management Services, Incorporated, and others. The claims revolve around allegations of racial discrimination in violation of 42 U.S.C. § 1982 and the Fair Housing Act (FHA), 42 U.S.C. § 3604, as well as FHA retaliation under § 3617. Defendant moved for summary judgment.
Statement of Uncontroverted Facts
The uncontroverted facts reveal that Property Management Services, Inc. (PMSI) manages 300 residential rental units, with many units occupied by tenants of diverse racial backgrounds. Plaintiff Watkins, a Black, African-American male, had rented two residential properties managed by PMSI and sought to participate in a rent-to-own housing program operated by the defendant. Yet Watkins alleges he was falsely informed by the defendants that no rent-to-own properties were available, specific properties he asked about were unavailable, and he had not followed PMSI’s procedure to apply. The facts presented show that PMSI’s rent-to-own program was indeed available to tenants, including Watkins, but he failed in identifying an available property to rent-to-own and never submitted an application due to alleged misrepresentations by PMSI employees.
Legal Analysis
Discrimination: The court used the burden-shifting analysis of McDonnell Douglas Corp. v. Green to evaluate the discrimination claims. Defendants argued that Watkins could not establish a prima facie case of discrimination or retaliation and that their reasons for not providing Watkins access to rent-to-own housing or terminating his lease were legitimate and non-pretextual. Even so, the court found that the defendants had not provided sufficient evidence to prove that Watkins was not qualified for the rent-to-own program or that their reasons for denying him access were legitimate. The court highlighted that the defendants identified no specific qualification Watkins lacked for participation in the program.
Retaliation: Regarding the retaliation claim under the FHA, the court followed a similar analytical framework. The defendants argued that Watkins had not engaged in a protected activity and that his month-to-month lease was terminated due to his history of rude and confrontational behavior, not as a retaliation for protected FHA activities. That said, the court found that Watkins had indeed engaged in protected activities by opposing practices he reasonably believed to be discriminatory. Despite the close temporal proximity between Watkins’s complaint and the termination of his tenancy, the court concluded that Watkins had not provided sufficient evidence to prove that the defendants’ proffered reason for eviction—his alleged misbehavior—was pretextual. In conclusion, the court granted summary judgment in part, finding for the defendants on the claims of racial discrimination and retaliation, but allowed Watkins’s FHA claim under 42 U.S.C. § 3604(d) regarding false representation of housing availability to remain pending.
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