Mary Valencia v. City of Springfield
883 F.3d 959
7th Cir.2018Background
- Springfield zoning code permits single-family detached residences and defines “family” (up to five unrelated persons) and separately defines “family care residence” (up to six unrelated persons with disabilities plus paid staff) with a 600-foot spacing requirement between family care residences.
- Individual Advocacy Group (IAG) arranged for three disabled clients to rent a house (the Noble home) and provide in-home supports (CILA model); a long-established group home (the Sparc home) sits 157 feet across the street.
- The City notified the landlord that the Noble home violated the 600-foot spacing rule and required the owners to apply for a Conditional Permitted Use (CPU); IAG and the landlords applied but the County Commission and Springfield Commission recommended denial and City Council denied the CPU.
- Plaintiffs sued under the FHA, ADA, and Rehabilitation Act alleging disparate treatment, disparate impact, and failure to provide a reasonable accommodation; they moved for a preliminary injunction to block eviction while the case proceeds.
- The district court granted a preliminary injunction, finding plaintiffs likely to succeed on claims of intentional discrimination and failure to reasonably accommodate; the City appealed but contested only likelihood of success on the merits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of a CPU and enforcement of the 600-foot rule violates fair-housing and disability statutes via failure to reasonably accommodate | CPU is a reasonable accommodation necessary to allow disabled clients equal opportunity to live in a residential neighborhood (CILA model; scarce group homes) | City contends code legitimately distinguishes family care residences and that three unrelated non-disabled adults would not be allowed, so plaintiffs seek a benefit not available to others | Court held plaintiffs showed a better-than-negligible likelihood of success on the reasonable-accommodation claim and preliminarily enjoined eviction |
| Whether the requested accommodation is reasonable (burden on City vs. benefit to residents) | Granting CPU imposes negligible financial/administrative burden and furthers integration; little evidence of adverse impact | City points to potential neighborhood/traffic/service burdens and clustering concerns | Court found the accommodation reasonable at the preliminary stage given minimal demonstrated burdens and lack of evidence of adverse effects |
| Whether accommodation is necessary to afford equal opportunity to use and enjoy housing | IAG showed necessity: limited supply of group homes, residents’ specialized needs, and community-based services required | City disputes necessity, arguing code’s definitions reflect neutral land-use aims and that plaintiffs seek a special benefit | Court found plaintiffs made a prima facie showing of necessity under FHAA standards at the preliminary-injunction stage |
| Whether speculative neighbor concerns can justify denial (stereotypes, safety) | Plaintiffs: neighbor fears are speculative/stereotypical and insufficient to show undue hardship | City: neighbors raise safety, traffic, and clustering concerns that warrant denial | Court held neighbor concerns were speculative and insufficient to overcome plaintiffs’ showing for preliminary relief |
Key Cases Cited
- Girl Scouts of Manitou Council, Inc. v. Girl Scouts of United States of Am., Inc., 549 F.3d 1079 (7th Cir.) (standard and deference in preliminary-injunction review)
- Whitaker v. Kenosha Unified Sch. Dist. No. 1 Bd. of Educ., 858 F.3d 1034 (7th Cir.) (likelihood-of-success threshold for preliminary injunctions)
- Oconomowoc Residential Programs v. City of Milwaukee, 300 F.3d 775 (7th Cir.) (zoning accommodation analysis under FHAA; variance as reasonable accommodation)
- Wis. Cmty. Servs., Inc. v. City of Milwaukee, 465 F.3d 737 (7th Cir.) (elements and allocation of proof for FHAA accommodation claims)
- Good Shepherd Manor Found., Inc. v. City of Momence, 323 F.3d 557 (7th Cir.) (FHAA accommodation obligation described)
- Dadian v. Village of Wilmette, 269 F.3d 831 (7th Cir.) (when a zoning waiver is a fundamental alteration and thus unreasonable)
- Bronk v. Ineichen, 54 F.3d 425 (7th Cir.) (necessity element: accommodation must ameliorate disability effects)
- Lapid-Laurel, L.L.C. v. Zoning Bd. of Adjustment, 284 F.3d 442 (3d Cir.) (burden-shifting and evidentiary allocation in zoning-accommodation claims)