Morris v. W. Hayden Estates First Addition Homeowners Ass'n, Inc., 382 F. Supp. 3d 1093

Background

Jeremy and Kristy Morris bought a home in West Hayden Estates and planned an elaborate public Christmas program (2015–2016) with extensive lights, buses, thousands of attendees, live animals, signage, amplified music, and solicitation for charity.
West Hayden Estates HOA (the Association) sent a January 15, 2015 letter (drafted in part by a former board member and edited by board members) expressing concern that the program might violate CC&Rs and raise issues for non-Christian residents and neighborhood safety.
Plaintiffs sued the Association under the Fair Housing Act (FHA) §§ 3604(b), 3604(c), and 3617 alleging religious discrimination and interference; a jury returned a verdict for Plaintiffs with damages but no final judgment was entered.
The Association sought renewed judgment as a matter of law under Fed. R. Civ. P. 50(b), and alternatively a new trial under Rule 59 and remittitur; the court reserved and tried the Association’s counterclaim seeking injunctive relief and fees for CC&R enforcement.
The court found the January 2015 letter, its drafting context, and other evidence insufficient to show the Association intentionally discriminated on the basis of religion, but found Plaintiffs’ Christmas program violated multiple Declaration (CC&R) provisions (e.g., external decorations, non‑residential use, nuisances, signage, hazardous activities, excessive lighting, keeping livestock).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Association is liable under Rule 50(b) (FHA claims)	January 2015 letter and surrounding conduct show intentional religious discrimination and unlawful statements	Letter and context show concern for CC&R compliance and religious pluralism, not intent to discriminate; insufficient evidence of intentional discrimination	Granted Rule 50(b) JMOL for Association — evidence insufficient for reasonable jury to find FHA violations
Sufficiency of evidence under FHA §3604(b), §3604(c), §3617	Letter and related testimony show discrimination in sale/terms, a preference statement, and interference/coercion	Letter context, lack of board approval, edits, membership composition, and Plaintiffs’ continued events undermine discriminatory intent and interference	Plaintiffs failed to prove elements of §§3604(b), 3604(c), 3617; verdict legally unsupported
Whether a new trial or remittitur is appropriate	Jury verdict should stand; damages awarded reflect plaintiff harm	Trial was tainted by improperly admitted/stricken testimony (threats) and credibility issues; damages speculative or inflated	In the alternative, court grants new trial under Rule 59 and/orders remittitur (reducing combined damages to nominal amounts unless Plaintiffs elect new trial)
Enforceability of CC&Rs; counterclaim for injunction and fees	Plaintiffs argued de‑annexation / continued program rights	Association asserted multiple CC&R violations and sought injunctive relief and attorney's fees	Court found Plaintiffs’ programs violated numerous CC&R provisions, permanently enjoined prohibited Christmas program activity, and ordered Plaintiffs to pay Association fees for counterclaim enforcement (fee petition to follow)

Key Cases Cited

Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000) (standard on judgment as a matter of law and weighing evidence)
Krechman v. County of Riverside, 723 F.3d 1104 (9th Cir. 2013) (no JMOL unless no legally sufficient basis for jury verdict)
Tortu v. Las Vegas Metropolitan Police Dep't, 556 F.3d 1075 (9th Cir. 2009) (Rule 50(a) prerequisite for Rule 50(b) renewal)
Kode v. Carlson, 596 F.3d 608 (9th Cir. 2010) (trial court may assess witness credibility on Rule 59 new‑trial inquiry)
Los Angeles Memorial Coliseum Comm'n v. Nat'l Football League, 791 F.2d 1356 (9th Cir. 1986) (remittitur appropriate when damages are grossly excessive or speculative)
Wetzel v. Glen St. Andrew Living Cmty., LLC, 901 F.3d 856 (7th Cir. 2018) (discussing landlord/manager liability for tenant discrimination where operator has enforcement arsenal)
Francis v. Kings Park Manor, Inc., 917 F.3d 109 (2d Cir. 2019) (landlord liability for failing to address racially hostile tenant conduct)