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/ ↗

Full Text

1,426 chars

artificial, arbitrary, and unnecessary barriers.” Id. at 521 (in-
ternal quotation marks omitted).
    Of course, a plaintiff need not meet all the elements of a
prima facie showing at the pleading stage. See Thomas v. JBS
Green Bay, Inc., 120 F.4th 1335, 1338 (7th Cir. 2024). Neverthe-
less, Inclusive Communities tells us that for an FHA disparate
impact claim a plaintiff must plead facts alleging a causal con-
nection between a policy or action and a disparate impact on
a protected class. See Inclusive Communities, 576 U.S. at 543 (“A
plaintiff who fails to allege facts at the pleading stage or pro-
duce statistical evidence demonstrating a causal connection
cannot make out a prima facie case of disparate impact.”). As
we have said in the Title VII context, 5 “[d]isparate-impact
plaintiffs are permitted to rely on a variety of statistical meth-
ods and comparisons to support their claims,” and “[a]t the
pleading stage, some basic allegations of this sort will suf-
fice.” Adams, 742 F.3d at 733.
    But Farhan’s complaint provides no such comparisons,
and she devotes little effort to developing a disparate impact
theory in her briefs before us. There is no allegation, for ex-
ample, about how many tenants are or may be impacted by
this rule—much less how many Palestinian tenants—or even
if the policy has been enforced beyond just her case. And
while Farhan states that other tenants keep flags, artwork,

Other Sections in This Document (43)

Full Text