Reese v. Park Place Condominium Homeowners Association I
Civil Action No. 2022-2660
D.D.C.Mar 21, 2025Background
- Plaintiff Allison Reese, an African-American homeowner in Park Place Condominiums (PPCA), experienced recurring property issues (e.g., termite and water damage) from 2014 to 2021.
- Reese claimed the PPCA failed to repair her unit or cover repairs under its master insurance policy, while allegedly approving such repairs for white owners.
- Under PPCA bylaws, the association is responsible only for building-wide issues, not unit-specific damage, and its insurance policy covers only casualty events.
- Reese frequently requested repairs; PPCA responded by inspecting her unit and making some repairs, but disputed broader liability and denied further coverage.
- Reese sued under the Fair Housing Act for race discrimination and retaliation; the court allowed only the race discrimination claim to proceed.
- PPCA moved for summary judgment, arguing there was no evidence of discrimination and that it followed legitimate, non-discriminatory policies per its bylaws and insurance contract.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was PPCA's denial of repairs/insurance racially discriminatory? | PPCA discriminated by providing repairs/insurance to white owners but not to Reese. | Denied repairs/insurance for legitimate, policy-based reasons equally to all; plaintiff failed to show different treatment. | No discrimination; summary judgment for PPCA |
| Did PPCA's actions violate its bylaws regarding repairs? | Bylaws obligated PPCA to repair foundation/structural issues in her unit. | No structural defect identified by Reese; responded appropriately per bylaws. | No violation; summary judgment for PPCA |
| Was there evidence of pretext for discrimination? | Claimed other white owners received coverage; cited insurance loss run reports. | No evidence presented by plaintiff; insurance records showed equal treatment. | No pretext; summary judgment for PPCA |
| Did Reese meet procedural/legal requirements for summary judgment opposition? | Submitted statements lacking record citations, no evidence of disputed facts. | Plaintiff failed to follow local rules; facts in PPCA's motion taken as undisputed. | Plaintiff failed to meet burden; judgment for PPCA |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard for genuine disputes of material fact)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination claims)
- Brady v. Office of Sergeant at Arms, 520 F.3d 490 (summary judgment focus after defendant articulates non-discriminatory reason)
- Celotex Corp. v. Catrett, 477 U.S. 317 (plaintiff's evidentiary burden at summary judgment)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (pretext in employment discrimination)