Manal Farhan v. 2715 NMA LLC (2025)

Citation: Manal Farhan v. 2715 NMA LLC (2025)
Parent Document: Manal Farhan v. 2715 NMA LLC (2025)
Jurisdiction: United States (federal)
Effective Date: 2025-12-04
Original Source: https://www.courtlistener.com/opinion/10747699/manal-farhan-v-2715-nma-llc/ ↗

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several state laws, alleging discrimination based on national
origin. Finding no plausible discrimination, the district court
granted defendants’ motion to dismiss under Federal Rule of
Civil Procedure 12(b)(6).
    We note at the outset that we decide this case on narrow
grounds, limited to the arguments presented by Farhan below
and on appeal. In opposing defendants’ motion to dismiss,
Farhan pursued a novel and unsupported theory of liability
under the FHA: that defendants’ application of a “neutrality”
policy requiring her, a Palestinian American, to remove a Pal-
estinian flag was national origin discrimination prohibited by
the FHA. She further asserted, erroneously, that a showing of
discriminatory intent was not required at the pleading stage
for her intentional discrimination claims, contrary to prece-
dent. See Texas Dep’t of Hous. and Cmty. Affairs v. Inclusive
Cmtys. Project, Inc., 576 U.S. 519, 524 (2015). While we stress
that the allegations in Farhan’s complaint could perhaps, pre-
sented or defended differently, state a claim for discrimina-
tion under the FHA, we affirm the district court’s dismissal.
                       I. Background
    At the pleading stage, we take all well-pled allegations in
the complaint as true. Kahn v. Walmart Inc., 107 F.4th 585, 593
(7th Cir. 2024). In 2021, Manal Farhan began leasing an apart-
ment from defendants. Farhan is a first-generation Palestinian
American. In October 2023, she handmade a Palestinian flag
and displayed it outside her window to show solidarity with
the Palestinian people. The flag, affixed to a small flagpole in-
side her unit, hung out of her window. Defendants accepted
Farhan’s November rent knowing that she had hung the flag
outside of her window.
No. 24-1532                                                  3

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