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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Section 3604

Citation
Section 3604
Parent Document
Francis v. Kings Park Manor, Inc., 944 F.3d 370 (2019)
Effective Date
2019-12-06

Other Sections in This Document (882)

Full Text

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13 The majority also cites fleetingly to Neudecker v. Boisclair Corp., 351 F.3d 361 (8th
Cir. 2003) (per curiam). But even assuming that Neudecker has any persuasive value, see
Halprin, 388 F.3d at 329 (noting that Neudecker was not a “considered holding”), the case
is simply inapposite. In Neudecker, the complaint alleged that the property manager’s
children had harassed the disabled plaintiff‐tenant, while the property managers themselves
disseminated the tenant’s private medical information to other tenants and engaged in acts
of harassment. Neudecker, 351 F.3d at 362–63. As these allegations indicate, the
landlord’s agents and their children, for whom the landlord might reasonably be held
vicariously liable, were thus charged with creating the hostile environment.