Saint-Jean v. Emigrant Mortg. Co., 337 F. Supp. 3d 186

Eight Black homeowners obtained Emigrant "STAR NINA" loans that required no income/asset verification and imposed an 18% default interest upon a single late payment; many had credit scores ≈600 or below.
Plaintiffs alleged the product was predatory and reverse‑redlined into Black and Hispanic communities via targeted broker relationships and advertising; several plaintiffs lost homes or were forced to sell.
A jury found Emigrant liable under the Fair Housing Act (FHA), Equal Credit Opportunity Act (ECOA), and New York City Human Rights Law (NYCHRL) and awarded $950,000 in compensatory damages; no punitive damages were assessed.
Post‑trial, both parties moved under Rules 50 and 59; defendants sought judgment as a matter of law or a new trial challenging sufficiency of evidence, jury instructions, expert testimony, timeliness, excusal of a juror, and damage excessiveness.
The court denied most defense challenges to liability and instructions, upheld plaintiffs’ experts and evidentiary showing of targeting/disparate impact, found the Saintils’ 2010 release not enforceable as against public policy, but concluded the jury’s damage awards were opaque and against the weight of the evidence, ordering a new trial limited to damages for some plaintiffs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence of discrimination	Emphasized expert testimony, marketing, broker incentives, targeted advertising, and statistical disparities supporting intentional targeting and disparate impact	Evidence was insufficient; verdict rested on speculation	Denied—jury could credit plaintiffs’ witnesses and experts; liability stands
Jury instructions on intent, pretext, disparate impact	Instructions permitted liability where loan was grossly unfavorable and race was a motivating factor; pretext instruction allowed inference from false explanations	Instructions misstated law, required animus, or relieved causation burden for disparate impact	Denied—court found instructions legally correct and consistent with Arlington Heights, Reeves, and Inclusive Communities principles
Enforceability of 2010 Saintils' release	Release was not knowing/voluntary and is void as against public policy given the discriminatory context and ineffective modification	Release barred Saintils’ claims as an affirmative defense	Court held release unenforceable as matter of law and ordered new trial on damages for the Saintils
Damages adequacy and need for retrial	Plaintiffs sought enforcement of jury awards and injunctive relief	Defendants argued awards were excessive, unsupported, and damages calculation inconsistent with amounts owed	Court found awards unclear relative to economic vs emotional losses; granted new trial on damages (injunctive relief deferred)

Cruz v. Local Union No. 3 of Int'l Bhd. of Elec. Workers, 34 F.3d 1148 (2d Cir.) (standard for Rule 50 review)
Wiercinski v. Mangia 57, Inc., 787 F.3d 106 (2d Cir.) (Rule 50 standard regarding absence of evidence)
Village of Arlington Heights v. Metropolitan Hous. Dev. Corp., 429 U.S. 252 (U.S. 1977) (framework for determining discriminatory intent)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (U.S. 2000) (permissibility of inferring discrimination from falsity of employer's explanation)
Texas Dep't of Hous. & Cmty. Affairs v. Inclusive Cmtys. Project, Inc., 135 S. Ct. 2507 (U.S. 2015) (disparate‑impact causation requirement)
Mhany Mgmt., Inc. v. County of Nassau, 819 F.3d 581 (2d Cir.) (FHA interpretation regarding unlawful motivating factors)
Boyd v. Lefrak Org., 509 F.2d 1110 (2d Cir.) (limits on showing disparate impact by income correlation)