Fed. Dist. Court MN Grants Summary Judgment to City on Plaintiffs’ Reasonable-Accommodation Claim under the FHA

This post was authored by Matthew Loescher, Esq.

Plaintiff Meraki Recovery Housing, LLC owned and operated a sober-living home in Coon Rapids, Minnesota. Plaintiffs Chad Moen, Scott Bestler, and Leland Dunn were recovering alcoholics who lived in the home. In early 2019, Meraki asked defendant City of Coon Rapids to exempt the sober home from an ordinance that limited the number of unrelated persons who could live together in a single-family house in a residential district. Following a public meeting, the Coon Rapids City Council denied Meraki’s request to permit ten people to live in the sober home rather than the six allowed under the ordinance. Plaintiffs brought claims against the City pursuant to the Fair Housing Act (“FHA”), 42 U.S.C. § 3601 et seq., and the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12101.

At the outset, the court noted that no evidence reflected that councilmembers were influenced by whatever discriminatory animus was expressed by community members. Instead, the City Council followed the recommendation of the City Planner, and there was no reason to believe that the City Planner acted with a discriminatory intent. The only direct evidence of the councilmembers’ motivations was their deposition testimony in which they provide plausible, non-discriminatory reasons for their votes and in which they deny acting in response to any anti-disabled comments by community members. Accordingly, the Court grants the City’s motion for summary judgment on plaintiffs’ disparate-treatment claim.

The court next found that plaintiffs failed to satisfy the “robust causality requirement” necessary to prevail on their disparate-impact claim under the FHA. Here, the challenged City ordinance was facially neutral and did not distinguish between residents who are disabled and residents who are not disabled. Furthermore, Plaintiffs did not offer any statistical evidence that the ordinance had a disproportionate impact on disabled individuals generally or recovering substance abusers specifically as Meraki’s sober home was the only sober home that had ever sought an exception to the ordinance.

Lastly, despite finding that Meraki’s request was reasonable, plaintiffs’ evidence was not sufficient to show that permitting ten residents to live in the sober home was necessary to give plaintiffs an equal opportunity to live in a residential neighborhood in Coon Rapids. The Court therefore granted summary judgment to the City on plaintiffs’ reasonable-accommodation claim.

Meraki Recovery Housing, LLC v City of Coon Rapids, 2021 WL 5567898 (D MN 11/29/2021)