Siguel v. King Farm Citizens Assembly, Inc.
8:22-cv-00672
| D. Maryland | Jul 3, 2024Background
- Edward Siguel sued King Farm Citizens Assembly (KFCA), associated individuals, their counsel, and the community’s architectural firm (BFMA Defendants), alleging violations under the Fair Housing Act (FHA) and Americans with Disabilities Act (ADA) concerning denied accommodation/modification requests, primarily regarding storage sheds.
- The Court previously granted in part and denied in part motions to dismiss the amended complaint, allowing only Count VI (related to storage sheds) to proceed against KFCA and BFMA, and dismissed all other claims against all other defendants.
- The BFMA Defendants moved for reconsideration, arguing that their limited contractual role as community architect (approving exterior changes for conformity with guidelines) should preclude liability.
- Siguel opposed, contending the prior ruling was correct and that BFMA’s recommendations materially contributed to the denial of a necessary accommodation due to disability under the FHA.
- The Court also addressed and allowed Siguel’s request to file a surreply, as BFMA raised new arguments in their reply brief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Count VI against BFMA Defendants states an FHA claim | Adequately pled BFMA’s role materially contributed to denial | BFMA’s limited role as architect—no affirmative discrimination or decision-making, thus no liability | Motion for reconsideration denied; Plaintiff states an FHA claim |
| Whether intent or only causation is required under FHA | Contribution to discriminatory act is sufficient | Plaintiff must plead discriminatory purpose or affirmative act | No intent required at this stage; causation/contribution suffices |
| Applicability of Howard v. City of Beavercreek | Factually distinguishable; here, sheds are necessary for disability | No FHA violation if plaintiff not denied neighborhood/house of choice as in Howard | Facts differ; Howard not controlling—motion denied |
| Standard for reconsidering interlocutory orders | No basis for reconsideration present | Prior ruling was clear error causing manifest injustice | No clear error/manif. injustice; relitigation not permitted |
Key Cases Cited
- Am. Canoe Ass’n v. Murphy Farms, Inc., 326 F.3d 505 (4th Cir. 2003) (standard for reconsideration of interlocutory orders)
- Bryant Woods Inn, Inc. v. Howard County, Md., 124 F.3d 597 (4th Cir. 1997) (requirements for FHA reasonable accommodation claims)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standards under Rule 8)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for motion to dismiss)