The City of Huntington v. The Lifehouse, Inc.et al
3:22-cv-00402
S.D.W. VaJul 13, 2023Background
- The City of Huntington enforces municipal zoning, building, fire codes and a rental registry; The Lifehouse, Inc. operates at least 14 Huntington properties described as sober‑living/recovery residences.
- Huntington alleges The Lifehouse repeatedly refused city inspections and claimed federal disability/fair‑housing statutes (ADA, FHA, RA, WVFHA) as a basis to avoid compliance with local zoning, building, and safety laws.
- Huntington also contends Lifehouse must satisfy WVARR certification inspection requirements for sober‑living homes.
- Huntington filed a declaratory judgment action asking the court to declare that federal statutes do not exempt Lifehouse from the City’s inspection and regulatory requirements and that Lifehouse’s asserted blanket accommodation is not reasonable.
- Lifehouse moved to dismiss, arguing lack of subject‑matter jurisdiction, absence of a justiciable Article III case or controversy (mootness/ripeness), failure to state a claim, and that the court should decline declaratory relief.
- The court denied the motion to dismiss, concluding federal‑question jurisdiction exists under the coercive‑action doctrine, the complaint’s factual allegations must be accepted at the pleading stage, and discretionary denial of declaratory relief was not warranted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Subject‑matter jurisdiction (federal question) | Lifehouse invoked federal statutes; therefore a federal controversy exists | Complaint seeks enforcement of state/local ordinances and only anticipates a federal defense—no federal question on face of complaint | Denied dismissal; court applied coercive‑action doctrine and found federal question jurisdiction exists |
| Justiciability (ripeness/mootness) | Dispute is live: Lifehouse allegedly refused inspections and asserted blanket exemptions | Lifehouse says it complied/inspections occurred, so controversy is moot or unripe | Denied dismissal; court accepts plaintiff’s well‑pleaded facts at pleading stage and will not resolve factual disputes now |
| Failure to state a claim (Rule 12(b)(6)) | Complaint plausibly seeks declaratory relief that Lifehouse lacks a blanket exemption | Defendant contends no live controversy and insufficient pleadings | Denied dismissal; allegations deemed sufficient under Twombly/Iqbal standards |
| Declaratory Judgment Act (discretionary abstention) | Declaratory relief will clarify rights and end uncertainty about blanket exemptions from local rules | Court would be asked to decide piecemeal future accommodation disputes | Denied dismissal; Quarles factors satisfied and no good reason to refuse jurisdiction |
Key Cases Cited
- Skelly Oil Co. v. Phillips Petroleum Co., 339 U.S. 667 (permissive nature of Declaratory Judgment Act does not itself create jurisdiction)
- Thigpen v. United States, 800 F.2d 393 (distinguishing facial vs. factual challenges to jurisdiction)
- Richmond, Fredericksburg & Potomac R.R. Co. v. United States, 945 F.2d 765 (courts may consider evidence outside pleadings on factual jurisdictional attack)
- Caterpillar Inc. v. Williams, 482 U.S. 386 (well‑pleaded complaint rule for federal‑question jurisdiction)
- Columbia Gas Transmission Corp. v. Drain, 237 F.3d 366 (coercive‑action doctrine: declaratory defendant’s federal claim can supply jurisdiction)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for complaints)
- Ashcroft v. Iqbal, 556 U.S. 662 (requirement to accept only well‑pleaded factual allegations)
- Aetna Cas. & Sur. Co. v. Quarles, 92 F.2d 321 (factors for exercising discretion under Declaratory Judgment Act)
- Nautilus Ins. Co. v. Winchester Homes, Inc., 15 F.3d 371 (district court may decline declaratory relief only for good reason)
- United States v. Sanchez‑Gomez, 138 S. Ct. 1532 (Article III requires a personal stake; mootness/standing principles)