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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In holding that Farhan’s claim for intentional discrimina-
tion is unsupported by her allegations and our FHA caselaw,
we do not foreclose the possibility that the circumstances of
her eviction could support a claim under the FHA if presented
differently. While the complaint does not support that de-
fendants knew her Palestinian heritage prior to enforcing the
“neutrality” policy, they certainly knew she was Palestinian
before evicting her. And the complaint alleges conflicting rea-
sons given for her eviction—whether it was because she hung
the flag in the first place or because the flag was outside her
window. Had Farhan pursued a claim that defendants moved
to evict her because she is Palestinian, this might be a different
case. See Swanson v. Citibank, N.A., 614 F.3d 400, 405 (7th Cir.
2010) (identifying who discriminated, the type of discrimina-
tion, and when it occurred is sufficient to state a claim for sim-
ple housing discrimination).
    But that is not the claim Farhan pursued, or ever at-
tempted to pursue, in opposing defendants’ motion to dis-
miss; we cannot credit it now. See County of McHenry v. Ins.
Co. of the West, 438 F.3d 813, 818 (7th Cir. 2006) (advising that
we “will not invent legal arguments for litigants”). Rather,
Farhan alleged in her complaint, and has maintained in her
briefs, that defendants “[i]ssu[ed] a notice of termination of
Plaintiff’s tenancy because she publicly displayed a flag of her
heritage … [and] because she would not adhere to Defend-
ants’ ‘neutrality’ policy.”

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