Rhode Island Commission for Human Rights v. Graul
120 F. Supp. 3d 110
| D.R.I. | 2015Background
- In March 2012 Briarwood Meadows (landlord) informed tenants Mardea Caulcrick-Grimes and Ernest Grimes they could not keep their newborn in a one‑bedroom unit because its occupancy policy limited bedrooms to two persons; their bedroom measured ~150 sq ft.
- Plaintiffs (Rhode Island Commission for Human Rights on behalf of the Grimeses and a tester) alleged familial‑status discrimination under the federal Fair Housing Act (FHA) and Rhode Island FHPA, asserting the policy had a disparate impact on families with children.
- Briarwood defended by asserting a state/building‑inspector interpretation required 170 sq ft for three occupants (70 for first occupant + 50 each additional), and also relied on HUD guidance (Keating memo) and asserted business concerns (wear, noise, systems).
- The Commission produced statistical expert analysis showing the policy disproportionately burdened households with children (large disparity ratios for 3–5 person households).
- Court held (motion practice) there were no genuine material facts in dispute as to liability and granted plaintiffs’ partial summary judgment on liability; damages to be determined later.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Administrative exhaustion / conciliation | Commission gave adequate notice and opportunity to conciliate; disparate‑impact theory was reasonably related to administrative charge | Defendants argued agency failed to plead/discuss disparate impact and thus exhaustion/conciliation was inadequate | Court: exhaustion satisfied; disparate‑impact theory reasonably within scope and conciliation obligation met |
| Disparate‑impact prima facie | Policy (2 persons/bedroom) is facially neutral but statistically and causally burdens families with children; expert statistics establish significant disparate impact | Defendants did not contest that policy disproportionately affects families for summary judgment purposes | Court: prima facie disparate impact established (robust, statistically significant disparities) |
| Legitimate business justification (defense burden) | N/A (plaintiffs argue defendants lack a legitimate, substantial justification) | Briarwood relied on Warwick inspector’s interpretation (170 sq ft), Keating memo, and speculative facility concerns | Court: proffered justifications fail—Warwick interpretation was incorrect as matter of law (State Code requires 150 sq ft for three occupants), Keating memo is non‑binding guidance, and defendants offered no evidence of systems/structural necessity |
| Liability under FHA & FHPA | Disparate impact under Inclusive Communities creates liability even without discriminatory intent | Defendants conceded disparate impact cognizable but argued policy was justified | Court: liability established under FHA and state FHPA; policy unlawful disparate impact |
Key Cases Cited
- Texas Dept. of Housing & Community Affairs v. Inclusive Communities Project, 135 S. Ct. 2507 (2015) (recognizes disparate‑impact liability under the FHA and sets burden‑shifting framework)
- Mach Mining, LLC v. EEOC, 135 S. Ct. 1645 (2015) (discusses agency conciliation obligations; distinguishes mandatory vs. discretionary language)
- Anderson v. Liberty Lobby, 477 U.S. 242 (1986) (summary judgment standard—no genuine issue of material fact)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden‑shifting framework for discrimination cases)
- Griggs v. Duke Power Co., 401 U.S. 424 (1971) (disparate‑impact theory in antidiscrimination law)
- Langlois v. Abington Housing Authority, 207 F.3d 43 (1st Cir. 2000) (legitimate and substantial goal standard in housing disparate‑impact context)
- United States v. Badgett, 976 F.2d 1176 (8th Cir. 1992) (one‑bedroom/one‑person type rules can violate FHA where they disparately impact families with children)
- St. Mary’s Honor Center v. Hicks, 509 U.S. 502 (1993) (defendant’s burden to articulate nondiscriminatory reasons)