Bouley v. Young-Sabourin
2005 U.S. Dist. LEXIS 25839, 2005 WL 950632, 394 F. Supp. 2d 675 (2005)
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Rule of Law:
Evicting a tenant shortly after the tenant becomes a victim of domestic violence may constitute a prima facie case of sex discrimination under the Fair Housing Act, creating a triable issue of fact for a jury to decide the landlord's true motive.
Facts:
- On August 1, 2003, Quinn Bouley, her husband Daniel Swedo, and their children rented an apartment from Jacqueline Young-Sabourin, who lived downstairs.
- For the first two and a half months of the tenancy, Bouley received no complaints from Young-Sabourin.
- On October 15, 2003, Bouley's husband criminally assaulted her in the apartment.
- Bouley called the police, who arrested her husband, and she subsequently obtained a restraining order against him.
- On the morning of October 18, 2003, Young-Sabourin visited Bouley's apartment, where Bouley claims Young-Sabourin attempted to discuss religion with her.
- Later that same day, Young-Sabourin delivered a letter to Bouley demanding that she vacate the apartment within 30 days.
- The eviction letter cited fear of continued violence, referencing a lease clause against unlawful or boisterous conduct, and also mentioned other minor lease issues such as storage on porches and damage to walls.
Procedural Posture:
- Plaintiff Quinn Bouley sued defendant Jacqueline Young-Sabourin in the U.S. District Court for the District of Vermont, alleging violations of the Fair Housing Act.
- After discovery, the defendant filed a Motion for Summary Judgment.
- The plaintiff then filed a Cross Motion for Summary Judgment.
- The District Court considered both motions simultaneously.
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Issue:
Does a landlord's decision to evict a tenant less than 72 hours after the tenant was a victim of domestic violence raise a genuine issue of material fact as to whether the eviction was motivated by unlawful sex discrimination in violation of the Fair Housing Act?
Opinions:
Majority - Murtha, District Judge
Yes, a landlord's decision to evict a tenant immediately following an incident of domestic violence raises a genuine issue of material fact regarding discriminatory motive. The court applied the McDonnell Douglas burden-shifting framework for discrimination claims. Bouley established a prima facie case because the eviction notice was issued less than 72 hours after her husband assaulted her; such timing supports an inference of discrimination. While Young-Sabourin offered non-discriminatory reasons for the eviction (fear of violence, other lease violations), the court found she presented little evidence of pre-existing problems with the tenancy. A reasonable jury could conclude from the timing and the falsity of the proffered explanations that the landlord's stated reasons were a pretext for unlawful discrimination based on sex (as a victim of domestic violence) or religion.
Analysis:
This ruling is significant for interpreting the Fair Housing Act to potentially include victims of domestic violence as a protected class under the category of sex discrimination. It establishes that the temporal proximity between an incident of domestic violence and an adverse housing action, such as eviction, can be sufficient evidence to establish a prima facie case of discrimination. This decision lowers the bar for such plaintiffs to survive summary judgment, ensuring that claims with disputed material facts about a landlord's motive will be decided by a jury rather than dismissed by a judge. It signals to landlords that evicting a tenant who is a victim of crime may carry significant legal risk if the motive can be plausibly linked to discrimination.
