Cinnamon Hills Youth Crisis Center, Inc. v. Saint George City
2012 U.S. App. LEXIS 13630
| 10th Cir. | 2012Background
- Cinnamon Hills operates a residential treatment facility in St. George, Utah and seeks to add a step-down program on the top floor of the Ambassador Inn, while continuing to operate the ground floor as a motel.
- Cinnamon Hills requested a variance from city zoning rules; the city denied, citing applicable code provisions governing motel stays and zoning in the C-3 zone.
- The city did not rely on § 10-5-3 (rural-location restrictions) in denying the variance, though the provision is discussed in the opinion.
- Cinnamon Hills sues under the Fair Housing Act, the Americans with Disabilities Act, and the Rehabilitation Act, alleging discrimination against the disabled.
- The district court granted summary judgment for the city, finding no material facts suggesting discrimination under any theory.
- The Tenth Circuit affirms, holding that the evidence fails to establish direct or indirect discrimination or a required reasonable accommodation under the FHA/ADA/RA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Direct discrimination proof viability | Cinnamon Hills asserts direct discriminatory intent from city actions. | City did not rely on disability; no facial bias shown in the decision. | Direct evidence insufficient; no reliance on § 10-5-3 in denial; no direct discrimination shown. |
| Disparate impact under McDonnell Douglas framework | Disparate impact shown by biased zoning outcomes against disabled. | No substantial disparate impact shown; comparators fail to demonstrate a policy-caused disparity. | No prima facie case; evidence fails to show a significant disparate effect from the challenged policy. |
| Failure to provide reasonable accommodation | Accommodation is necessary to ensure equal housing opportunity for the disabled. | No housing opportunity available to the disabled that is comparable to others; accommodation not needed. | Accommodation not necessary where no comparable housing opportunity exists; relief denied. |
Key Cases Cited
- Reinhart v. Lincoln Cnty., 482 F.3d 1225 (10th Cir. 2007) (disparate-impact elements require statistical evidence and proper comparators)
- Bryant Woods Inn, Inc. v. Howard County, 124 F.3d 597 (4th Cir. 1997) (necessity of accommodation linked to equal housing opportunity)
- Village of Arlington Heights v. Metropolitan Housing Dev. Corp., 429 U.S. 252 (1987) (prima facie case and inferential burden in discrimination claims)
- Ramsey v. City & Cnty. of Denver, 907 F.2d 1004 (10th Cir. 1990) (direct evidence requires explicit discriminatory statements or policy reliance)
- Shorter v. ICG Holdings, Inc., 188 F.3d 1204 (10th Cir. 1999) (direct evidence standard (overruled on other grounds in later cases))
- Almond v. Unified School Dist. No. 501, 665 F.3d 1174 (10th Cir. 2011) (requirements for prima facie case under Title VII analogy in discrimination claims)