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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based rule that burdens a protected class. She is also right to
note that Bloch was decided at summary judgment, and we
cannot expect the same factual development in her claims as
we observed in Bloch. But she errs by ignoring Bloch’s holding
about what constitutes intentional discrimination under the
FHA. In Bloch, we held that even where the association
harshly burdened the Blochs’ religious expression by reinter-
preting their hallway rules to ban mezuzot, the Blochs could
only proceed on a disparate treatment claim if they proved
“that the Association reinterpreted the Rules with Jews in
mind.” 587 F.3d at 785. “[E]vidence of an adverse impact on
observant Jews” was not enough; the Blochs needed to “show
that the Association reinterpreted the Hallway Rules to apply
to mezuzot ‘because of’ and not merely ‘in spite of’ the Blochs’
religion.” Id.
    Applying Bloch to this case, Farhan must plausibly allege
that defendants created the “neutrality” policy, or applied it
against her, “‘because of’ and not merely ‘in spite of’” her na-
tional origin. Id. The complaint makes no such allegation. In-
deed, it makes no allegation that defendants were even aware
of her national origin prior to the enforcement of the “neutral-
ity” policy. Farhan alleges that she did not have the Palestin-
ian flag in her window before October 2023, and the only al-
leged communication regarding her Palestinian heritage oc-
curred after the building manager instructed her to remove
the flag. 2

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