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Gilligan v. Jamco Dev. Corp
No. 95-56290 (9th Cir. Mar. 5, 1997) ; Clearinghouse Number: 52204
Description
Ninth Circuit Reinstates Challenge to Landlord’s Refusal to Rent to Welfare Recipients
Abstract
The Ninth Circuit has reversed the district court’s order
granting defendant landlord’s motion to dismiss this Fair
Housing Act action. Plaintiffs allege that defendant refuses
applications from all prospective tenants who receive AFDC
benefits. They claim that this restriction constitutes
discrimination on the basis of familial status in violation of the
Fair Housing Act, 42 U.S.C. §§ 3604, 3613. Plaintiffs
argue that the source-of-income restriction, even if it is neutral
on its face, has the effect of discriminating against families with
children. The district court dismissed plaintiffs’ complaint,
finding that plaintiffs had failed to allege that they were
financially qualified to rent at defendant’s apartment
complex. Reversing, the court of appeals held that
plaintiffs’ allegations were sufficient to state a claim
under the Fair Housing Act. In so ruling, the court concluded that
the district court erred in requiring plaintiffs to allege each
element of a prima facie case under the Act in the pleadings.
