Fair Housing Center of the Greater Palm Beaches, Inc. v. Sonoma Bay Community Homeowners Ass'n, Inc., 136 F. Supp. 3d 1364

Discrimination action under the federal Fair Housing Act and Florida Fair Housing Act alleging familial status discrimination in rental housing at Sonoma Bay and Marsh Harbour in Riviera Beach, Florida.
Undisputed fact: from 2010 onward, rental applications required submitting student report cards for persons under 18 (Report Card Requirement).
Undisputed fact: Rules and Regulations prohibited certain attire, loitering on streets, and restricted under-18s to home or patio after sunset (Proper Attire Rule, Loitering Rule, Curfew Rule).
Plaintiffs seek declaratory relief, injunctive relief, and damages to stop discriminatory practices and remedy effects of the alleged unlawful provisions.
Court evaluates whether these policies facially or practically discriminate under 42 U.S.C. § 3604(a)-(c) and grants/denies partial summary judgment accordingly.
The court applies Rule 56 standards, evaluating whether disputed facts require trial versus legal questions suitable for summary disposition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the Report Card Requirement violate § 3604(a) as a matter of law?	Plaintiffs contend the rule acts as a barrier to families with children.	Defendants argue no direct refusal to rent; rule may not equate to denial.	Denied; issue requires fact-finder decision (not resolution on summary judgment).
Do the Proper Attire Rule, Loitering Rule, and Curfew Rule violate § 3604(b) as a matter of law?	Loitering and Curfew discriminately target children.	Rules may be neutral or justifiable for safety; intent not dispositive.	Loitering and Curfew: judgment for plaintiffs; Proper Attire unresolved on record.
Do the Report Card Requirement and Proper Attire Rule violate § 3604(c) on ordinary reader standard?	Advertisements or writings indicate discrimination against families with children.	Wording may be ambiguous or apply to all residents; no clear advertisement of discrimination.	Report Card and Proper Attire: trial needed; Loitering/Curfew: discrimination established for § 3604(c).
Must the Loitering and Curfew Rules be analyzed under least restrictive means?	Rules discriminate on its face against children; least restrictive means not satisfied.	Safety/crime-prevention could justify restrictions.	Least restrictive means not satisfied; these rules gravely discriminatory.

United States v. Hunter, 459 F.2d 205 (4th Cir. 1972) (ordinary reader standard for § 3604(c))
Community Housing, Inc. v. City of Boise, 490 F.3d 1041 (9th Cir. 2007) (safety concerns must address tangible risks, not stereotypes)