City of Kansas City, Mo. v. Yarco Co., Inc.
2010 WL 4395393
8th Cir.2010Background
- City of Kansas City sued Yarco and Churchill for discriminatory curfew at a KC apartment complex under FHA, state, and local laws.
- HUD forwarded the FHA complaint to the City for investigation; Yarco opted for judicial proceedings, leading to federal suit removal.
- District court granted judgment on the pleadings in Yarco's favor, finding no plausible discriminatory intent.
- Court of Appeals vacates and remands for further proceedings, noting jurisdictional issues and potential remand to state court.
- Yarco's lease imposed an 8:30 p.m. curfew for anyone under 18; City claimed FHA violation based on families with children.
- Court analyzes standing and concludes the City lacks Article III standing to pursue FHA claims; federal jurisdiction may be lacking.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether City has standing to pursue FHA claim | Yarco alleges City lacks injury in fact, City argues sovereign/enforcement interest. | Yarco contends no concrete injury to City; FHA claim improper for municipal standing. | City lacks standing; FHA claim cannot proceed in federal court. |
| Whether federal jurisdiction exists over state/local claims | City seeks federal review of FHA and related claims. | No federal question jurisdiction beyond FHA; standalone state/local claims lack basis. | No original federal jurisdiction; claims remanded to state court. |
| Whether supplemental jurisdiction applies | Supplemental jurisdiction could permit adjudication of related state claims. | Since FHA claim is absent, no basis for supplemental jurisdiction. | Supplemental jurisdiction does not apply; must remand entire case. |
| Proper remedy when district court lacks jurisdiction | Case should proceed in federal court if jurisdiction exists. | Case should be remanded to state court for lack of jurisdiction. | Remand to state court; district court to remand to state court per 28 U.S.C. § 1447(c). |
Key Cases Cited
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requires injury, causation, redressability)
- Medalie v. Bayer Corp., 510 F.3d 828 (8th Cir.2007) (standing as threshold, jurisdictional prerequisite)
- United States v. Hays, 515 U.S. 737 (1995) (federal courts must determine subject matter jurisdiction sua sponte)
- Gladstone Realtors v. Village of Bellwood, 441 U.S. 91 (1979) (standing for municipal injury under FHA context described)
- Vermont Agency of Natural Resources v. United States ex rel. Stevens, 529 U.S. 765 (2000) (government injury and assignability concepts for standing)
- Int'l Primate Protection League v. Adm'rs of Tulane Educ. Fund, 500 U.S. 72 (1991) (standing and redressability principles in federal cases)
- ASARCO Inc. v. Kadish, 490 U.S. 605 (1989) (federal courts' reach in federal-question or related matters)
- City of Clarkson Valley v. Mineta, 495 F.3d 567 (8th Cir.2007) (standing and jurisdictional considerations in the Eighth Circuit)