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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Farhan also argued that she had adequately stated a claim
for relief under a disparate impact theory, because defend-
ants’ “neutrality” policy “has a disproportionate impact on
Palestinian tenants by definition.” She argued that under de-
fendants’ policy other tenants could hang the flag of their
homeland, but she, a Palestinian American, could not. Thus,
even if defendants’ discrimination was based upon political
viewpoint, the fact that their policy disproportionately af-
fected Palestinian and Israeli tenants meant that she had ar-
ticulated an FHA disparate impact claim.
    The district court granted defendants’ motion to dismiss,
holding that Farhan’s complaint did not plausibly allege that
she “was discriminated against based on her national origin,
rather than her political beliefs in support of the Palestinian
cause.” The court noted that Farhan did not allege any facts
about the national origins of other tenants who were allowed
to display flags and artwork in their windows. It rejected the
proposition that holding or displaying a flag is necessarily
emblematic of a person’s national origin such that banning
the flag is discrimination based on national origin. And since
Farhan alleged that she told defendants she was Palestinian
American only after the property manager told her to take the
flag down, there was no reasonable inference that defendants
were aware of her national origin prior to enforcing the pol-
icy.
    The district court also held that Farhan had not stated a
claim for relief under § 3617 of the FHA because she had not
alleged even one action based on discriminatory animus, let
alone a “pattern of harassment motivated by discriminatory
intent.” The district court dismissed Farhan’s FHA claims
with prejudice and declined to exercise supplemental
6                                                     No. 24-1532

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