Charles Hollis, Jr. v. Chestnut Bend Homeowners Ass'n
2014 U.S. App. LEXIS 14392
| 6th Cir. | 2014Background
- Hollis couple sought to build a sunroom in Chestnut Bend for their two children with Down syndrome; CBHA’s ARC governed architectural approvals and required detailed submissions on Form 080810.
- ARC decisions often issued boilerplate reasons or no reasons, with review by the CBHA board; approval could be withheld for aesthetic concerns, and a final approval hinged on the board’s consent.
- Hollises submitted four sunroom proposals; initial applications were deemed incomplete, then rejected for aesthetics, with subsequent rounds contending over material and roof type; the fourth proposal faced renewed ARC/board scrutiny and a threat of pursuing legal options.
- In late 2011–early 2012, after negotiations and counsel involvement, the ARC/board discussed and drafted a near-approval conditioned on a shingle roof rather than metal, with the Hollises eventually requesting more favorable terms.
- The Hollises moved to a new home and filed suit February 2, 2012, alleging FHA discrimination under 42 U.S.C. § 3604; district court dismissed the Hollises’ personal-capacity claims and granted CBHA summary judgment on the next-friend claim under a McDonnell Douglas framework, which this court vacates and remands.
- The appellate court holds that McDonnell Douglas is inapplicable to FHA reasonable-modification claims and remands to apply the proper framework, with standing analysis addressed later in the opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| What framework governs FHA reasonable-modification claims | Hollis seeks McDonnell Douglas framework (intent-based) | CBHA supports McDonnell Douglas approach | McDonnell Douglas inapplicable; use reasonableness/necessity framework |
| What is the proper framework for analysis of reasonable-modification claims | Plaintiff argues for plaintiff-burden on reasonableness/necessity | Defendant argues for defendant burden-shifting under McDonnell Douglas | Plaintiff bears ultimate burden; summary judgment can shift to defendant if no genuine issue of material fact |
| Whether Hollis has standing to sue individually in addition to next friends | Hollis’s injuries from moving and home value reductions confer standing | Standing limited to next-friends claim for children | Hollises have Article III standing to sue individually for pecuniary injuries in addition to next-friends standing |
| Whether the district court properly dismissed personal-capacity claims | District court misapplied standing | Standing was lacking for individual claims | Remand to address personal-capacity claims under correct framework |
| Whether the CBHA met its burden on summary judgment | Plaintiff evidence supports pretext/insufficient reasons; modification needed | Aesthetic concerns and process were legitimate; no pretext | Remand to apply appropriate summary-judgment framework and assess material facts |
Key Cases Cited
- Groner v. Golden Gate Gardens Apartments, 250 F.3d 1039 (6th Cir. 2001) (burden on plaintiff to prove reasonableness; summary judgment framework explained)
- Smith & Lee Assocs., Inc. v. City of Taylor, 102 F.3d 781 (6th Cir. 1996) (elements of reasonable accommodation; reasonableness/necessity focus)
- Lindsay v. Yates, 578 F.3d 407 (6th Cir. 2009) (employment-discrimination precedent; not controlling for modification claims)
- Havens Realty Corp. v. Coleman, 455 U.S. 363 (U.S. 1982) (standing requirement; injury in fact for FHA claims)
- Groe0ner v. Golden Gate Gardens Apartments, 250 F.3d 1039 (6th Cir. 2001) (summary judgment framework; burden on plaintiff to prove reasonableness)
- Wis. Cmty. Servs., Inc. v. City of Milwaukee, 465 F.3d 737 (7th Cir. 2006) (reasonableness/necessity analysis in modifications)