Holley v. Meyer

123 S. Ct. 824 (2003) ; Clearinghouse Number: 54025

Description

U.S. Supreme Court Holds That Corporate Owner Is Not Vicariously Liable Under Fair Housing Act for Employee’s Discriminatory Actions

Abstract

The U.S. Supreme Court held that the Fair Housing Act imposed liability without fault on an employer in accordance with traditional agency principles, that is, the Act normally imposed vicarious liability on the corporation but not on its officers or owners. Respondents, an interracial couple, tried to buy a house listed for sale by a real estate corporation. A corporate salesman, allegedly for racially discriminatory reasons, prevented respondents from buying the house. After filing suit in federal court against salesman and real estate corporation, respondents filed a separate suit against petitioner, the corporation’s president, sole shareholder, and licensed “officer/broker.” The district court, consolidating the lawsuits and dismissing the claims against petitioner, found that the Act did not impose personal vicarious liability on a corporate officer. Reversing the district court, the Ninth Circuit held corporate owners and officers to be vicariously liable for an employee’s violations of the Act because the Act specified liability for those who directed or controlled or had the right to direct or control another’s conduct regarding the sale of a dwelling or provision of brokerage services. Reversing the Ninth Circuit, the Supreme Court found that Congress said nothing in the Act or its legislative history about extending traditional vicarious liability in this manner. Moreover, the U.S. Department of Housing and Urban Development specified that ordinary vicarious liability rules applied, and the Court ordinarily deferred to an administering agency’s reasonable statutory interpretation. Finding that nothing in the Act’s language or legislative history supported the existence of a corporate owner’s or officer’s “nondelegable duty” not to discriminate, the Court vacated the Ninth Circuit’s judgment and remanded the case.

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Attorney Information
Docket Date
2003-01-22 00:00:00+00:00

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