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City of Phoenix v. Roberts
No. CV 98-15151 (Ariz. Super. Ct. Maricopa County Dec. 14, 1998). ; Clearinghouse Number: 52205
Description
Public Housing Authority Has Duty to Attempt to Accommodate Tenant’s Mental Disability Before Seeking to Evict Him
Abstract
The court dismissed the eviction of defendant tenant from public
housing because plaintiff housing department failed to accommodate
reasonably tenant’s mental disability in violation of section
3604(f)(3)(B) of the Fair Housing Amendments Act. Tenant had had a
long history of mental illness. According to tenant’s expert
witness, he fit the criteria for paranoid schizophrenia. In
response to a series of notices of cleanliness inspections, which
tenant considered to be intrusive and unnecessary, tenant wrote a
letter to housing department. Although tenant believed the letter
to be merely an expression of his opinion, housing department staff
believed it to contain threats of violence against them. Housing
department asked tenant to volunteer for an evaluation of his
mental status, and he refused. Subsequently housing department
initiated an involuntary psychiatric evaluation/detention. Based on
tenant’s letter, housing department sought to evict tenant
for criminal activity and threats of violence. The court found that
housing department had a duty to attempt to accommodate
tenant’s disability in light of his written threats. The
court held that tenant could be subject to eviction only if he
constituted a threat to others after housing department made
reasonable efforts to accommodate tenant. Housing
department’s motion for reconsideration was denied.
