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/10747698/manal-farhan-v-2715-nma-llc/ ↗

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Ordinance. She sought money damages, injunctive relief, and
a declaration that defendants waived any alleged breach of
the lease by accepting Farhan’s rent. Defendants removed the
case to federal court. They answered one of the state law
claims, filed a counterclaim for eviction against Farhan, and
moved to dismiss the remainder of Farhan’s claims for failure
to state a claim.
    In opposing defendants’ motion, Farhan pursued a theory
that “requiring tenants to stay neutral in a conflict concerning
their home countries is national origin discrimination.” She
argued that because defendants’ “neutrality” policy related
only to the Israel-Palestine conflict, and did not ban, for ex-
ample, Ukrainian or Russian flags in tenant windows, “this
would not be happening if she flew a Ukrainian flag in her
window instead of a Palestinian one.” She analogized her
claim to that of the plaintiffs in Bloch v. Frischholz, 587 F.3d 771
(7th Cir. 2009) (en banc). In Bloch, Jewish plaintiffs sued after
their condominium association applied a policy prohibiting
“objects of any sort … outside Unit entrance doors” to repeat-
edly remove the Blochs’ mezuzot from their external door-
posts. Id. at 773. There, we held that the plaintiffs’ claims of
intentional discrimination could survive summary judgment
because the association’s selective application of its rules
“transformed it from a neutral one to one that was targeted
exclusively at observant Jewish residents.” Id. at 783. Farhan
argued the same was true here—that the defendants’ policy
of neutrality on the Israel-Palestine conflict was being “inter-
preted in a manner that constitutes intentional discrimina-
tion.” But she maintained that no specific allegation of dis-
criminatory intent was required to pursue a disparate treat-
ment claim under Bloch.
No. 24-1532                                                  5

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