932 F. Supp. 2d 683
M.D. La.2013Background
- Oxford House, Inc. and related plaintiffs sue the City of Baton Rouge alleging FHA, ADA, and §1983 violations based on zoning enforcement and alleged discriminatory conduct.
- Oxford House operates seventeen homes in Baton Rouge, including Oxford House-Drusilla and Oxford House-Shawn, both in A-1 single-family zones.
- The City’s Unified Development Code defines Special Homes with a two-part test and requires a reasonable accommodation process; Oxford House seeks to be treated as a reasonable accommodation rather than a licensed, 24-hour staffed group home.
- Plaintiffs argue residents are handicapped under FHA/ADA and that the City denied reasonable accommodations, thereby discriminating and violating federal law.
- The Court grants summary judgment to Oxford House on FHA/ADA disparate treatment and reasonable accommodation theories, grants partial relief with respect to FHA/ADA retaliation and §1983 assertions, and defers judgment on the §1983 claim.
- HUD previously concluded that Baton Rouge violated the FHA by denying Oxford House’s reasonable accommodation request, a finding the Court finds persuasive
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the City violate FHA/ADA by denying a reasonable accommodation? | Oxford House seeks accommodation; City denied and conditioned on licensing/24-hour staffing. | City followed procedures; accommodation not warranted given licensing/staffing gaps. | Yes; City violated FHA by denying a reasonable accommodation. |
| Are Oxford House residents handicapped under FHA/ADA? | Residents are alcohol/drug recovery individuals, impairments that may constitute handicaps. | Per Toyota per se disabilities not established; must show substantial limitation case-by-case. | Handicap/disability found; case-by-case evaluation applicable. |
| Is there viable disparate-treatment or facial-discrimination claim against the City’s Special Homes? | Special Homes provision discriminates against disabled residents. | Ordinance not facially discriminatory; second half allows accommodation; applied neutrally. | There is facially discriminatory potential in the first portion of the Special Homes definition. |
| Is there a retaliation claim under FHA/ADA? | Letters citing occupancy violations followed protected activity (HUD complaint and suit). | Occupancy letters are routine compliance; causation not shown. | Prima facie retaliation shown; summary judgment granted to Plaintiffs on retaliation claim. |
| Does §1983 defeat or survive the City’s actions regarding due process or liberty/property interests? | City’s enforcement pattern violated due process; group homes treated unequally. | City actions rationally related to zoning and occupancy requirements. | Section 1983 claim survived summary judgment review; court declines final resolution. |
Key Cases Cited
- Arlington Heights v. Metropolitan Housing Dev. Corp., 429 U.S. 252 (U.S. 1977) (framework for analyzing discriminatory intent factors)
- Toyota Motor Mfg., Kentucky, Inc. v. Williams, 534 U.S. 184 (U.S. 2002) (overruled strict Toyota standard; case-by-case disability assessment required)
- Schwarz v. City of Treasure Island, 544 F.3d 1201 (11th Cir. 2008) (three FHA elements: refusal, reasonableness, necessity; precedent for accommodations)
- RECAP, Inc. v. City of Middletown, 294 F.3d 35 (2d Cir. 2002) (recognizes impairment and need for accommodations in disability housing cases)
- Marbrunak, Inc. v. City of Stow, 974 F.2d 43 (6th Cir. 1992) (facially discriminatory housing regulation against developmentally disabled in single-family zones)