Robinson v. District of Columbia

United States District Court for the District of Columbia · 2024 · Torts

TortsProcedural Due ProcessFair Housing ActSupplemental JurisdictionRule 15Rule 12(b)(6)Fair Housing Actreasonable accommodation

Facts

Robinson, a resident of Kia's Place IV, a District-funded homeless shelter program operated by ECS, alleged that shelter employees falsely accused him of misconduct in April 2021 and terminated his placement. He sought administrative review under D.C.'s Homeless Services Reform Act, and a DHS administrative review officer found a procedural flaw and ordered him reinstated. Before his planned return, ECS employees obtained a temporary anti-stalking order, and Robinson was denied entry when he came back. Robinson alleged that defendants failed to accommodate his ADHD, PTSD, and depressive disorder, denied him shelter and access to his belongings, and thereby violated federal law and D.C. law.

Issue

Did Robinson's proposed amended complaint plausibly state a federal Fair Housing Act reasonable-accommodation claim and a federal procedural due process claim, such that amendment would not be futile? If those federal claims failed in whole or in substantial part, should the federal court retain supplemental jurisdiction over the remaining claims?

Rule

A proposed amendment is futile if the amended complaint would not withstand a Rule 12(b)(6) motion. To plead a Fair Housing Act reasonable-accommodation claim, a plaintiff must allege a statutory handicap, the defendant's knowledge of it, that the accommodation may be necessary for equal use and enjoyment of the dwelling, and refusal of a requested accommodation; a request for accommodation must actually be made, though not in any particular form. To plead procedural due process, a plaintiff must plausibly allege a protected property interest and deprivation of that interest without constitutionally adequate process; where all or nearly all federal claims fail and state-law claims substantially predominate, a court may decline supplemental jurisdiction and remand.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nina Alvarez sued a supportive-housing operator in Baltimore in federal court and, after a motion to dismiss, sought leave to amend. Her proposed amended complaint alleges that she has bipolar disorder and anxiety, that staff had her medical records, and that they forced her out after a confrontation. The amendment says only that the operator should have accommodated her so she could stay, without describing any accommodation she asked for.

How should the court most likely rule on the motion to amend as to the federal housing-discrimination claim?

Explanation. A proposed amendment is futile if it would not survive Rule 12(b)(6). For a Fair Housing Act reasonable-accommodation claim, the plaintiff must plead, among other things, that she requested an accommodation and that the defendant refused it. A general allegation that the provider should have accommodated her so she could remain housed is not enough when the complaint does not identify what accommodation was requested. (Derived from Robinson v. District of Columbia (n.d.).)