Caron Foundation of Florida, Inc. v. City of Delray Beach
2012 U.S. Dist. LEXIS 92256
S.D. Fla.2012Background
- Caron Foundation sues the City of Delray Beach alleging FHA and ADA violations related to sober-living homes on Ocean Drive.
- Caron sought reasonable accommodations and injunctive relief; the City amended its transient use ordinance and reasonable accommodation rules.
- Two Ocean Drive houses were acquired; Caron requested seven unrelated residents for housing therapy, prompting city review.
- Public opposition included active community comments and alleged discriminatory statements by planning board and officials.
- The City revised the transient use ordinance (three turn-overs/year) and altered the reasonable accommodation process for the Second Ocean Drive House.
- The court evaluates standing, ripeness, and discrimination theories to determine injunctive relief and scope of enforcement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing of Caron as a housing provider | Caron and its clients are protected disabled individuals under FHA/ADA; Caron has standing as a service provider. | Standing hinges on plaintiffs’ status and direct injury; need to show concrete, individualized harm. | Caron has standing as a provider of services for protected individuals. |
| Ripeness of reasonable accommodation claim | City denied seven-resident accommodation; claim ripe. | City asked for more information; no final denial; claim not ripe. | Reasonable accommodation claim not ripe. |
| Disparate treatment claim viability | City’s amendments target disabled residents; discriminatory intent. | Ordinance facially neutral; no intent shown. | Disparate treatment claim not barred by ripeness; but requires showing discriminatory intent. |
| Likelihood of success on disparate treatment claim | Historical sequence and discriminatory comments indicate intent. | Proffered nondiscriminatory reasons not pretextual. | Court finds substantial likelihood of discrimination in amendment to transient use ordinance. |
| Irreparable harm and balance of equities | Amended ordinance renders program inoperable; irreparable harm to clients. | Enforcement protects neighborhood character and zoning. | Preliminary injunction granted in part to restrain enforcement of amended ordinance and to ease processing without discrimination. |
Key Cases Cited
- Arlington Heights v. Metropolitan Housing Development Corp., 429 U.S. 252 (1977) (factors for discriminatory intent in municipal decisions)
- Schwarz v. City of Treasure Island, 544 F.3d 1201 (11th Cir.2008) (validates need to assess timing and intent in transient-use/rehab facility context)
- Oconomowoc Residential Programs v. City of Milwaukee, 300 F.3d 775 (7th Cir.2002) (ADA/FHA protections apply to zoning decisions; sober living as dwelling)
- Johnson Controls, Inc. (International Union v. Johnson Controls, Inc.), 499 U.S. 187 (1991) (standards for evaluating discriminatory effects and intent)
- Bryant Woods Inn, Inc. v. Howard County, 124 F.3d 597 (4th Cir.1997) (reasonableness/necessity standard for reasonable accommodations)