Craven, Amanda v. Knaak, Karyn
3:24-cv-00579
W.D. Wis.Jun 30, 2025Background
- Amanda Craven, a disabled resident of Dane County, Wisconsin, received a federally funded housing choice voucher managed by the Dane County Housing Authority (DCHA).
- Craven alleged she was denied participation in a HUD homeownership program and experienced interference and delays in using her voucher, leading to periods of homelessness.
- Craven claimed DCHA and its staff required unnecessary repeated requests for payment standard exceptions and failed to respond to her inquiries after she filed a housing discrimination claim.
- Craven alleged the DCHA interfered with her doctor’s support for a reasonable accommodation and that she was denied due process by not receiving hearings or appeal opportunities after terse denials.
- She brought claims under the Fair Housing Act (FHA), Americans with Disabilities Act (ADA), Fourteenth Amendment (due process), and Wisconsin tort law for tortious interference.
- The court screened the complaint, as Craven was proceeding pro se and in forma pauperis, but found the complaint did not state plausible claims and failed to comply with Rule 8's pleading requirements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Disability discrimination (FHA, ADA) | DCHA discriminated by denying program access and interfering with voucher use | Not specified in the opinion | Complaint lacks sufficient facts; fails to state a plausible claim |
| Failure to provide reasonable accommodation | DCHA failed to accommodate by denying office space and requiring repeated exceptions | Not specified in the opinion | Factual detail too sparse to support a reasonable accommodation claim |
| Due process (Fourteenth Amendment) | DCHA denied hearings/appeals after denials | Not specified in the opinion | No specific deprivations or process failures described; claim dismissed |
| Tortious interference | DCHA interfered with her doctor and landlord relationships | Not specified in the opinion | Allegations too speculative; no specific interaction alleged |
Key Cases Cited
- Arnett v. Webster, 658 F.3d 742 (7th Cir. 2011) (pro se complaints are construed liberally, but must state plausible claims)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaints must plausibly state a claim for relief)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaints must provide enough factual matter to state a plausible claim)
- Swanson v. Citibank, N.A., 614 F.3d 400 (7th Cir. 2010) (plaintiffs must specify the type, participants, and timing of housing discrimination)
- Wagoner v. Lemmon, 778 F.3d 586 (7th Cir. 2015) (ADA claim elements for services denial based on disability)
- Oconomowoc Residential Programs v. City of Milwaukee, 300 F.3d 775 (7th Cir. 2002) (elements of FHA failure-to-accommodate claims)
- Khan v. Bland, 630 F.3d 519 (7th Cir. 2010) (three elements necessary for procedural due process claims under § 1983)