Groner v. Golden Gate Gardens Apartments
2001 WL 557980, 250 F.3d 1039 (2001)
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Rule of Law:
Under the Fair Housing Act, a plaintiff-tenant bears the burden of proving that a proposed accommodation for their disability is reasonable. An accommodation is not reasonable if it imposes an undue financial or administrative burden on the landlord, requires a fundamental alteration of the premises, or infringes on the rights of other tenants.
Facts:
- Howard Groner, who suffers from schizophrenia and depression, rented an apartment from Golden Gate Gardens Apartments, which was aware of his disability.
- Approximately four months after he moved in, Groner's upstairs neighbor, Diane Arter, began making complaints to the apartment manager, Kathleen Boyle, about Groner screaming and slamming doors at all hours of the night.
- Boyle repeatedly contacted Groner's social worker, Ray Gonzalez, who acknowledged the problem and advised Groner to 'scream into the pillow.'
- Over the next year and a half, Arter registered approximately ten to twelve complaints as the disturbances continued.
- Golden Gate soundproofed Groner’s front door in an attempt to lessen the noise and also offered to let Arter move to a different apartment, which she refused.
- Due to the persistent noise, Golden Gate converted Groner's annual lease to a month-to-month tenancy.
- After further complaints, Golden Gate notified Groner that his tenancy was being terminated.
- Gonzalez requested lease renewal as an accommodation, and Golden Gate granted a temporary extension conditioned on receiving no further complaints, but the noise persisted, leading to a final notice to vacate.
Procedural Posture:
- Howard Groner and the Metropolitan Strategy Group sued Golden Gate Gardens Apartments in the U.S. District Court, alleging violations of the federal Fair Housing Act and Ohio law.
- Groner’s motion for an emergency injunction to prevent eviction was denied as moot.
- Golden Gate filed a motion for summary judgment on all of Groner’s claims.
- The district court denied Groner’s motion to file a supplemental reply.
- The district court granted Golden Gate’s motion for summary judgment and dismissed the case.
- Groner, as the appellant, appealed the district court's grant of summary judgment to the U.S. Court of Appeals for the Sixth Circuit.
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Issue:
Does a landlord violate the Fair Housing Act's reasonable accommodation requirement by proceeding with an eviction of a tenant with a mental disability whose behavior, directly related to that disability, consistently and significantly disturbs another tenant, after the tenant fails to propose a workable, reasonable accommodation?
Opinions:
Majority - Gilman, Circuit Judge.
No, the landlord does not violate the Fair Housing Act. The court held that a landlord is not required to provide an accommodation that is not reasonable, and the tenant bears the burden of proving that their proposed accommodation is, in fact, reasonable. The court reasoned that cases interpreting the Rehabilitation Act, from which the FHA's accommodation standard is derived, place the burden on the plaintiff to show an accommodation is reasonable. Here, Groner's proposed accommodations—such as having the landlord immediately contact his social worker for every complaint or moving him to another unit—were not reasonable because they had either already proven ineffective or would impose an undue administrative burden on the landlord and likely infringe upon the rights of another tenant. The court emphasized that a reasonable accommodation does not require a landlord to sacrifice the rights of other tenants to quiet enjoyment or to do 'everything humanly possible' to accommodate a disabled person. Because Golden Gate had made efforts to resolve the issue and Groner failed to propose a feasible accommodation that wouldn't unduly burden the landlord or other tenants, the eviction was not discriminatory.
Analysis:
This decision is significant for establishing in the Sixth Circuit that the burden of proof is on the plaintiff-tenant to demonstrate the reasonableness of a requested accommodation under the Fair Housing Act. It clarifies the limits of a landlord's duty, establishing that the 'reasonableness' of an accommodation must be balanced against the financial and administrative burdens on the landlord and the rights of other tenants. The ruling provides landlords with a defense against accommodation requests that are unworkable, ineffective, or infringe upon the quiet enjoyment of other residents. Future cases in this jurisdiction will require tenants to come forward with concrete, feasible proposals for accommodation and evidence that these proposals are reasonable.
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