emotional harm in housing discrimination cases
United States v. Witherington (S.D. On October 15, 2020, the court entered a consent order resolving United States v. ASAP Towing & Storage Company (M.D. (E.D. The case was referred to the Division after the Department of Housing and Urban Development (HUD) received a complaint, conducted an investigation, and issued a charge of discrimination. Under the terms of the agreement, J & R Associates will establish a $70,000 settlement fund to compensate victims of the discriminatory practices. Tex. Makinen v. City of New York, 167 F. Supp. ), United States v. Wells Fargo Bank, N.A., d/b/a Wells Fargo Dealer Services, Inc. (C.D. (W.D.N.Y. Tex.) The complaint contended that the bank requested information from the applicant concerning the nature and severity of their disabilities when she sought a mortgage loan. Ill.), a Fair Housing Act pattern or practice/election case which was referred to the Division by the Department of Housing and Urban Development (HUD) alleging discrimination on the basis of disability. Cal.). Pa.), United States & Willborn v. Sabbia (N.D. Ill.). ), United States v. AIG Federal Savings Bank and Wilmington Finance, Inc. (D. La.). March 31, 2019), a sexual harassment/retaliation case, the court - in addition to denying defendant's motion for judgment as a matter of law on plaintiff's retaliation claim - next evaluated the jury's damage awards to plaintiff ($750,000 in emotional distress damages, $500,000 in punitive damages). Furthermore, individuals who engage in discriminatory housing practices, or knowingly aid or abet such discrimination, may face criminal charges dictated by federal law. ), The Roman Catholic Archdiocese of Kansas City in Kansas v. The City of Mission Woods, Kansas (D. Kan.), Sailak, LLC v. Forsyth County, Georgia (N.D. Ga.), Sherman Avenue Tenants' Association v. District of Columbia (D.D.C. United States v. PHH Mortgage Corp. (D. N.J.). Village of Arlington Heights v. Metropolitan Housing Development Corp. (1977) In this case, the Court declared that proof of a racially discriminatory intent is required in claim that race was . Victor M. Goode & Conrad Johnson, ADC v. Westchester County, New York (S.D.N.Y. 1143 The settlement agreement requires United Communities to pay $45,001.78 in damages to 13 servicemembers and a $17,500 civil penalty to the United States. In its filed Complaint, CFC alleges that the Village barred it from operating in the C-1 district, even though the Villages zoning law permits other similarly situated secular assembly uses to operate in the district, including municipal buildings, charitable and social clubs, and theaters. (M.D. On September 14, 2020, the court entered a consent order in United States v. PR III/Broadstone Blake Street, LLC, et al. 42 USC 1981a (b) The amendment also added the right to a trial by jury for compensatory and punitive damages. -BUT- If the proceeds you receive for emotional distress or mental anguish do not originate from a personal physical injury or physical sickness, you must include them in your income. During this meeting, the plaintiff again told defendant Guy Emery that he was looking at the apartment on behalf of his mother who used a wheelchair. On November 20, 2000, a unanimous three-judge panel joined three other Courts of Appeal holding that the Commerce Clause authorizes Congress to regulate the housing market. Infliction of emotional distress is a tort, which is an action (or inaction) someone takes that injures someone else. and Capstone, Inc. discriminated on the basis of disability by failing to design and construct five Boise complexes in accordance with the Fair Housing Act's accessibility requirements for new multifamily housing. The agreement also includes injunctive relief, including permanently barring Hatfield from participating in the rental, sale, or financing of residential properties. This case is based on evidence generated by the Division's Fair Housing Testing Program. (the individuals with disabilities who would have lived in the home intervened in the case through private counsel and settled separately). Neb. ), United States v. Loventhal Silver Riverdale LLC (S.D.N.Y. Menu The complaint, which was filed silumtaneously with the consent order on September 28, 2007, alleged a pattern or practice of discrimination and a denial of rights to a group of persons on the basis of familial status in violation of the Fair Housing Actby the owners and management of Phoenix Village Apartments, located in Fort Smith, Arkansas. Pa.), United States v. Stonecleave Village Ass'n, Inc. (D. The settlement agreement requires PHH to pay $750,000 in damages to the servicemembers ($125,000 per servicemember). By Josh Bowers. The original complaint, filed on December 23, 2010, alleged that the defendants engaged in a pattern or practice of sexual harassment in housing at properties that they own and operate in and around Toledo, Ohio in violation of the Fair Housing Act. Cal. ), United States v. SDC Legend Communities, Inc. (W.D. ), United States v. Lawrence Properties, Inc. (M.D. Va.). (D. Ind. The consent decree provides for a non-discrimination injunction; revisions to defendants' rental policies and practices; posting of non-discrimination notices; training; record keeping and reporting; payment of $39,000 in damages and attorney's fees to the intervening private plaintiffs; and payment of an $11,000 civil penalty. On November 19, 2019, the court entered a consent decree in United States v. Higgins (S.D.N.Y.). Part II discusses the issue of bias in the process of reviewing discrimination cases from the perspective of critical race theory and recent social science data. Tex.). ), United States. On December 12, 2008, Homecomings Financial, LLC and GMAC Mortgage, LLC and their affiliates, including but not limited to GMAC Bank and Residential Funding Company, LLC, agreed to resolve our Servicemembers Civil Relief Act (SCRA) investigation. Yoder-Shrader's rental practices had initially been investigated by testers from the Fair Housing Council of Orange County, which subsequently filed a complaint against the company with the Department of Housing and Urban Development. The United States' complaint, filed on March 2, 2005, alleged that Peter Altmayer intimidated and harassed his next door neighbors, and their two minor children, on the basis of their religion (Jewish) and national origins (Israeli and Mexican). On March 16, 2010, the case settled before the court ruled on the issue raised inthe United Statesamicus brief. The Fair Housing Act is a federal law that prohibits housing and housing-related discrimination based on race, color, religion, national origin, gender, familial status, or disability. The complaint alleges that Twin Creek engaged in a pattern or practice of violating the Servicemembers Civil Relief Act (SCRA), 50 U.S.C. Hargraves v. Capitol City Mortgage Corp. The complaint alleges that the owners and managers of residential rental housing in Honolulu, Hawaii, refused to rent to families with children, in violation of the Fair Housing Act. After the City denied the Islamic Associations application to build a religious cemetery, the United States opened an investigation of the Citys actions in September 2017. The case was referred to the Division after the Department of Housing and Urban Development (HUD) received a complaint, conducted an investigation and issued a charge of discrimination. As part of the agreement, the City has agreed to provide training to its officials and employees about their obligations under RLUIPA and to notify the public about the Citys compliance with RLUIPA in its zoning and land use actions. ), United States v. Glenwood Management Corp. United States v. Board of Commissioners of the County of Montezuma (D. Colo.), United States v. Bonanza Springs, LLC (D. Nev.), United States v. Borough of Bound Brook, New Jersey (D. N.J.), United States v. Boston Housing Authority (D. Discrimination in housing has numerous consequences. Respondent Danielian will conduct annual in-house training for a period of three years to its employees involved in the design of multi-family dwellings. ), Southwest Key Programs, Inc. v. City of Escondido (S.D. The complaint alleges that the DOA discriminated on the basis of disability by failing to grant a reasonable accommodation to its no-pets policy to a HUD complainant, and alleges that DOA engaged in a pattern or practice of discrimination and/or a denial of rights against a group of persons for adopting a discriminatory policy and refusing to grant reasonable accommodations to persons with disabilities who need assistance animals. United States v. Pacific Properties and Dev. Tex.). ), United States v. Miller-Valentine Operations (S.D. (E.D. Va.), National Fair Housing Alliance, Inc. v. Spanos (N.D. Neb. As we have seen, housing discrimination comes in many forms, and often happens on multiple bases simultaneously. The complaint alleged that the Countys denial of the permit imposed a substantial burden on the Muslim congregations exercise of religion that was not narrowly tailored to further a compelling governmental interest. (S.D. (S.D. United States v. San Diego Family Housing, LLC (S.D. Chicago Commission on Human Relations . Texas Department of Housing and Community Affairs v. The Inclusive Communities Project, Inc. Complaint For Employment or Workplace Discrimination and Sexual Harassment, Housing Discrimination: U.S. Supreme Court Cases, Set different terms, conditions, or privileges for the sale or rental of a dwelling, Provide different housing services or facilities, Falsely deny that housing is available for inspection, sale, or rental, For profit, persuade owners to sell, or rent (blockbusting) or. The case was referred to the Division after the Department of Housing and Urban Development (HUD) received a complaint, conducted an investigation and issued a charge of discrimination. On July 28, 2020, the United States filed a complaint in United States v. Vandelay Group (E.D. The complaint also alleged that the defendant retaliated by serving a notice of eviction on the complainant after she made a complaint of housing discrimination to HUD. Mass. The consent decree requires defendants to pay $11,000 in damages to the estate of the complainant. The complaint alleges that the Defendants discriminated against the Complainants on the basis of disability by failing to grant a reasonable accommodation to its breed restriction policy to allow a daughter with PTSD to visit her mother at the mobile home community with her assistance animal and that the Defendants interfered with their fair housing rights by banning the daughter and evicting the mother from the community. ), United States v. Flagstar Corporation and Denny's (N.D. Under the terms of the consent decree the Village shall: pay $5,000 to each of the forty-four households in Green Oaks who were relocated as a result of the Village's acquisition and/or removal of buildings prior to the entry of this consent decree; establish a fund in the amount of $100,000 for private plaintiffs representing the class pursuant to the notice; pay $1, 000 to any household displaced in the center core of Green Oaks Courts pursuant to the implementation of the Plan; pay $60,000 to Hispanics United of DuPage County, the Hispanic Council, and the Leadership Council for Metropolitan Open Communities; pay $30,000 into an interest-bearing account to be used in furtherance of fair housing in Addison by enhancing awareness of the requirements of federal fair housing laws. In addition, the complaint alleged that the defendants provided transportation as an amenity and that until 2013, that transportation was inaccessible to people who used wheelchairs in violation of the Fair Housing Act. This fianl consent decree resolves allegations against the architect of the Verdesian, SLCE Architects, LLP. The bank could provide no reason for carving out areas with large concentrations of minority individuals from its lending areas. (E.D.N.Y. of Nebraska (D. ), United States v. Woodcliff Lake, NJ (D .N.J. ), United States v. Deposit Guaranty National Bank (N.D. Mass. The settlement agreement requires Nissan to pay $2,937,971 in damages to servicemembers and a $62,029 civil penalty to the United States, for a total of $3 million. (D.D.C.). The United States' complaint, which was filed on December 19, 2005, alleged that Ronald Bathrick engaged in discrimination on the basis of sex, including severe, pervasive, and unwelcome sexual harassment in rental units he owned and managed in Hastings and St. Paul, Minnesota. The complaint also alleged that the Township only permitted places of worship on properties zoned as part of the Institutional District, and no properties with that zoning designation were available in that district when the Bensalem Masjid acquired the property. Ohio), United States, NFHA & LIHS v. Uvaydov (E.D.N.Y. (E.D.N.C.). Because of this refusal, the complainant allegedly was forced to move out. Tex.). Fla.). Iowa). The complaint, filed on July 14, 2008, alleged that the Condominium Association and the members of its Board of Directors in located in Munster, Indiana, maintained a written policy that prohibited families with minor children from living in the condominium complex The complaint further alleged that members of the Board made oral statements indicating a preference against families with children and that the policy was enforced in a discriminatory manner to exclude African-Americans from living in the condominium complex. The settlement agreement requires Citi to pay $907,000 in compensation to the servicemembers whose cars were illegally repossessed and to remove the repossessions from the servicemembers credit reports. ), United States v. Brooklyn Park 73rd Leased Housing Assoc., LLC (D. Minn.). ), United States v. Landings Real Estate Group (D. Conn.), United States v. Larkspur, LLC (S.D.N.Y. relief for intentional discrimination under the Rehabilitation and Affordable Care Acts 15 A. Compensatory damages are available to rectify intentional discrimination16 B. Emotional-distress damages are a standard form of compensatory damages for intentional discrimination 19 C. Emotional-distress damages are The complaint, which was filed on November 16, 2005, alleged that the defendants refused to sell property located in the Village of Sherman, County of Sagamon, Illinois to the HUD complainants because the planned use for the property was as a group home for adults with developmental disabilities. On October 27, 2017, the jury returned a verdict of $43,500 in favor of the United States in United States v. DeRaffele (D. ), United States v. Township of Jackson and Jackson Planning Board (D. N.J.), United States v. Toyota Motor Credit Corp. (C.D. The case was referred to the Division after the Department of Housing and Urban Development (HUD) received a complaint, conducted an investigation, and issued a charge of discrimination. United States v. Bedford Development LLC (S.D.N.Y.). The case was referred to the Division after the Department of Housing and Urban Development (HUD) received a complaint, conducted an investigation, and issued a charge of discrimination. (S.D.N.Y. United States v. Highland Management Group, Inc. (D. Minn.). Civ. (D. Colo.). ), United States v. Thomas Development Co. (D. Idaho), United States v. TK Properties, LLC (D. 3601-3619 and 3631, and also known as the Fair Housing Act ("FHA"), prohibits discrimination in the lease, sale, or rental of housing on the basis of race, color, religion, sex, familial status, or national origin. On July 14, 2020, the court entered a consent order in United States v. 111 East 88th Partners (S.D.N.Y.). The complaint, which was filed on January 2, 2020, alleges that a condo homeowners association refused, over a period of six months, to allow a resident to live with her emotional assistance dog. (E.D.N.C. ), in support of the Congregation's motion for summary judgment in this Religious Land Use and Institutionalized Persons Act (RLUIPA) suit. Cal. Cal. On February 22, 2008, the United States filed a brief as amicus curiae to address legal issues raised by defendants, without taking a position on the merits of the summary judgment motion. C.R.C.L.Rev. United States and State of North Carolina v. Auto Fare, Inc. The decree also requires the defendants to pay $15,000 in civil penalties and contributions to a fund to further housing opportunities for persons with disabilities. Mich.), United States v. Related Companies (S.D.N.Y. Mich.), United States v. CitiFinancial Credit Co. (N.D. Md.). It provides for standard injunctive relief, a payment of $15,000 to compensate aggrieved persons, and a $30,000 civil penalty. Ala.), United States v. Associates National Bank (D. Meeting with a lawyer can help you understand your options and how to best protect your rights. Constitutional Law Commons, Home | The complaint, which was filed simultaneously with the consent decree by the United States Attorney's Office on April 19, 2005, alleged that the owners of an apartment building in Carol Stream, Illinois refused to make a reasonable accommodation to allow the HUD complainant to move from a one-bedroom unit to a two-bedroom unit (which had fewer steps and had more room for her therapeutic equipment), even though she had obtained a Section 8 voucher for a two-bedroom unit. This, and future civil rights legislation, would be characterized by the development of a national agenda . One area that was not included in this initial congressional effort, but later found its way into the legislative agenda, was the subject of housing discrimination. Auth. ), United States v. Seattle Housing Authority (W.D. One woman testified that Johnson refused to give her keys to her apartment until she agreed to have sex with him. $2.5 million Medical Malpractice resulting in wrongful death in failing to timely diagnose and treat lung cancer of a 48-year-old mother of four . ), United States v. Housing Authority of the City of Aurora (D. Colo.), United States v. Housing Authority of the City of Bridgeport, d/b/a Park City Communities (D. Conn.). ), United States v. Southeastern Community and Family Services, Inc. (Wesley) (M.D.N.C. On or about January 22, 1990, the Village Board of Trustees adopted Ordinance Number 233, entitled Village of Hatch Municipal Zoning Ordinance ("the 1990 zoning ordinance"). On December 2, 2004, the court entered a consent decree resolving United States v. Beaudet (D. Minn.) The Defendant, David R. Beaudet, has owned and managed numerous single-family rental homes throughout St. Paul since 1990. In August 2018, the United States notified the City that it had concluded that the City had violated RLUIPA and intended to file suit, and offered the City an opportunity to negotiate a resolution. Cal. ), United States v. Lucky Joy Restaurant, Inc. In addition, racially targeted loans that are designed to fail make housing unavailable because of race since the borrowers are likely to lose their homes through foreclosure. The complaint, filed on June 15, 1995, alleged that from 1986, the Village of Hatch, through its Mayor and Board of Trustees, has engaged in a course of municipal action intended to prevent permanent resident aliens of Mexican national origin from living in the Village. The complaint alleges that United Communities, which provides on-base military housing at Joint Base McGuire-Dix-Lakehurst in New Jersey, engaged in a pattern or practice of violating the Servicemembers Civil Relief Act (SCRA), 50 U.S.C. P.R. Okla.), a Fair Housing Act HUD election case that alleged discrimination based on disability. On November 21, 2018, the United States filed an amended complaint in United States v. Pelfrey (W.D. Tex. Ohio), United States v. Fifth Third Mortgage (M.D. Fair housing laws open doors, break down barriers, and repair the harm caused by discriminatory housing practices. They awarded damages based on their "Yes" to "Do you find by a preponderance of the evidence that the defendants violated the Fair Housing Act by Guy Emery's statement, either to (CN) or (DNA), with respect to the rental of an apartment, that indicated a preference, limitations, or discrimination, or an intention to make such a preference, limitation, or discrimination, on the basis that (DNA) used a wheelchair." Ky.), United States v. Andrian-Zeminides Architects, Ltd. (N.D. Ill.), United States v. Apartment and Home Hunters, Inc. (E.D. Neb.). Equal Employment Opportunity United States v. Cincinnati Capital Partners LXXIII, LLC (S.D. United States v. Hillman Housing Corp. The complaint, filed October 26, 2011, alleged that Nicolai Quinn, the manager of the apartment complex, told prospective African-American renters that apartments were not available when they were, while telling prospective white renters that there were apartments available. Mich.). The United States Statement of Interest argues that the facts alleged by the Ramapough state substantial burden and unequal treatment claims under RLUIPA. Many state agencies have also adopted the principle prohibitions of Title VIII, and with its 1988 amendments, the law has been strengthened, broadened, and attorney's fee provisions have permitted the private bar to play a primary role in its enforcement. Va.). It also alleged that the Housing Authority failed to meet its communitys need for accessible units many years after federal regulations and a voluntary compliance agreement with HUD required it to do so. entered the consent decree in United States v. Barrett (M.D. Ind. Conrad Johnson, Columbia Law SchoolFollow. v. Township of Mount Holly (3rd Cir. The complaint alleges that the defendants discriminated on the basis of familial status by adopting policies and practices that prohibited children from using amenities at the apartment complex without adult supervision. In the consent order, filed on June 20, 2001, the Defendants agreed to pay $5,000 in damages to the complainant and her son. The case was referred to the Division after the Department of Housing and Urban Development (HUD) received a complaint, conducted an investigation, and issued a charge of discrimination. The consent order requires the defendants to: pay $70,000 to the complainants; admit that their actions violated the Fair Housing Act; issue a letter of apology; pay $10,000 to the widow of a Triumvera resident who used a wheelchair during the last years of his life, and pay a $3,500 civil penalty. Mass.). On September 1,2016, the court entered a consent decree in United States v. Parkside East, Inc. (E.D. After respondents were contacted by HUD regarding a complaint of design and construction deficiencies, respondents took corrective actions at an approximate cost of $41,000. (E.D.N.Y.). (E.D. The complaint alleges that the Town violated the Fair Housing Act by refusing to grant the request for a reasonable accommodation or reasonable modification by a homeowner, who sought a zoning variance to build a carport on her property because of her disability. ), United States v. The Home Loan Auditors (N.D. Stress and health. ), United States v. Wheeling Housing Authority (N.D. W. Va.), United States v. The Whitacres, LLC (N.D. W. Va.), United States v. WHPC-DWR, LLC (E.D. Ark. The federal Fair Housing Act of 1968 and the federal Fair Housing Act Amendments Act of 1988 prohibit discrimination on the basis of the following criteria (called "protected categories"): race or color; religion; national origin; familial status or ageincludes families with children under the age of 18 and pregnant women . Housing Discrimination: Types, Examples, and Actions to Take. 1 In doing so, the majority declines to follow an 11 . ), supporting the servicemember's argument that there is a private right of action to enforce the provision of the SCRA that requires lienholders to get a court order before enforcing a lien on a servicemember's property. Tenn.), Metropolitan St. Louis Equal Housing Opportunity Council v. Gundacker Real Estate, Co. (E.D. Enterprises, Inc. ("Aristocrat") (E.D. Mass. Tenn.). ), United States v. Fifth Third Bank (S.D. the Fair Housing Act (FHA . United States v. Creekside Condominium Owners Assn (D. Colo.). The complaint, which was filed on May 26, 2015, alleged that the City implemented and enforced spacing requirements and overly restrictive fire code regulations for small group homes for individuals with intellectual or developmental disabilities, in violation of the Fair Housing Act and the Americans with Disabilities Act.The consent decree requires the City to pay $435,000 in monetary relief to 11 aggrieved individuals and a $15,000 civil penalty. ), United States v. Inland Empire Builders (D. Nev.). On January 7, 2020, the court entered a consent order in United States v. Creekside Condominium Owners Assn (D. Colo.). Fair Housing rights apply to all housing types, including apartments, single-family homes, condominiums, and cooperative housing. On February 10, 1998, the court entered a consent decree resolving United States v. Village of Addison (N.D. Ill.). Despite the federal housing discrimination law designed to protect vulnerable groups, rising living costs make it difficult for too many people to keep a roof over their heads. Accessibility Statement. Tenn.). On March 15, 2019, the United States Attorneys Office entered into a settlement agreement to resolve United States v. Bedford Development (S.D.N.Y. 3604(f)(3)(C), and the Americans with Disabilities Act, 42 U.S.C. The complaint involves Adam Community Centers (Adam) efforts to establish an Islamic place of worship in Troy at a building previously used as a restaurant and banquet hall. ), United States v. Town of St. John (N.D. The defendants must also offer to pay current owners to correct certain inaccessible features within condominium units, including those found in bathrooms and kitchens. Tex.). On March 8, 2002, the United States filed a consent order along with the complaint in United States v. Badeen (D. Kan.) alleging discrimination on the basis of race, color, and national origin. Available at: ), a case alleging that Quicken Loans discriminated against borrowers with disabilities by requiring that they provide a letter from a doctor as a condition of their loans. Pa.), United States v. City of Joliet (N.D. Ill.), United States v. City of Lake Station (N.D. There are limits on the amount of compensatory and punitive damages a person can recover. Nonetheless, it is categorically prohibited in light of the broader ban on discrimination based on familial status. The case was referred to the Division after the Department of Housing and Urban Development (HUD) received a complaint, conducted an investigation, and issued a charge of discrimination. Cal. ), a Fair Housing Act pattern-or-practice/election case. ), United States v. Hillside Park Real Estate, LLC (N.D.N.Y. Ind. ), United States v. Horsley and Horsely Construction (D. Idaho), United States v. Housing Authority of Baltimore City (D. Court Awards of Emotional Distress Damages Over $100,000 . The complaint also alleges that the series of advertisements amounts to a pattern or practice of familial status discrimination. The case came to the Division after the Department of Housing and Urban Development (HUD) received complaints, conducted an investigation, and issued a charge of discrimination. as defendants. Ohio), United States v. Nationwide Nevada (D. Nev.), United States v. Nejam Properties (S.D. Ill.), United States v. Webster AV Management, LLC (S.D.N.Y. ), United States v. Town of Oyster Bay (E.D.N.Y. The Division's investigation revealed that F & K had promulgated and posted a policy in its clubs prohibiting head coverings with the exception of cowboy hats and baseball caps. Co. (W.D. The pattern or practice/election complaint, which was filed on March 3, 2017, alleged that the property manager and owners of rental properties in Edmonds, Washington, discriminated on the basis of familial status in violation of the Fair Housing Act. Discrimination is a public health issue. On August 10, 2018, the United States entered into a settlement agreement resolving United States v. Irvin (W.D. Tex. Cal. (S.D.N.Y. As stated by Senator Walter Mondale, one of its sponsors, the Act would replace the nation's ghettos by "truly integrated and balanced living patterns." On March 8, 1999, with the court entered a consent order in United States v. Pinewood Associates (D. Nev.). Mich.), alleging that the City of Troy violated the substantial burden and equal terms provisions of the Religious Land Use and Institutionalized Persons Act (RLUIPA). Defendant Barnason is a Level 3 sex offender who was hired after being released from prison for various sexual offenses. The settlement agreement obligates the real estate company, First Boston Real Estate, to implement a non-discriminatory policy, which will be displayed in its offices and distributed to any persons who inquire about the availability of any properties, as well as to all agents. This is a research file with cases from a variety of sources . 1974). The settlement agreement requires Hatfield to pay $550,000 in damages to 17 actual or prospective residents of Hatfields properties and a $50,000 civil penalty. The consent decree will remain in effect for three years. This article briefly describes the Fair Housing Act and the Fair Housing Act Amendments of 1988 and the problem of tenant hoarding in society and under the law. Its lending areas, with the court entered a consent order in United States of. Home Loan Auditors ( N.D also added the emotional harm in housing discrimination cases to a pattern or practice of familial discrimination... 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