Section 3604

Citation: Section 3604
Parent Document: Francis v. Kings Park Manor, Inc., 944 F.3d 370 (2019)
Jurisdiction: United States (federal)
Effective Date: 2019-12-06
Original Source: https://www.courtlistener.com/opinion/4684833/francis-v-kings-park-manor-inc/ ↗

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9 Unlike Title VII, which provides a cause of action against specified employers who
discriminate, the FHA does not identify a class of potential defendants who can be
charged—so that not only landlords, but also public housing authorities, cooperative
boards, block associations, real estate agents, or, indeed, anyone, is potentially liable.
Thus, in Modesto, on which the majority relies, the Ninth Circuit held that a plaintiff could
pursue a § 3604(b) claim alleging discrimination by a local government in the provision
of law enforcement protection to homeowners or renters, and notwithstanding the lack of
any connection to a residence’s sale or lease. See Modesto, 583 F.3d at 713–15; cf. Ga. State
Conference of the NAACP v. City of LaGrange, 940 F.3d 627, 633–34 (11th Cir. 2019) (rejecting
the Ninth Circuit’s “expansive view of [municipal] services covered by §3604(b),” but
holding that a municipality’s discriminatory provision of water, gas, and electricity
services is actionable under the FHA because those utilities are “closely tied” to the sale
or rental of a dwelling and essential to its habitability).

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