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/ ↗

Full Text

1,878 chars

jurisdiction over Farhan’s state law claims, dismissing those
claims without prejudice and entering judgment. Farhan then
filed this appeal.
                        II. Discussion
    The Fair Housing Act prohibits discrimination in the pro-
vision and maintenance of housing. Section 3604(a) of the
FHA prohibits refusing to sell, rent, or “otherwise make una-
vailable or deny” a dwelling based on race, color, religion,
sex, familial status, or national origin. 42 U.S.C. § 3604(a). Sec-
tion 3604(b) makes it unlawful “[t]o discriminate against any
person in the terms, conditions, or privileges of sale or rental
of a dwelling, or in the provision of services or facilities in
connection therewith, because of” a protected status. 42
U.S.C. § 3604(b). Section 3604’s protections apply even after
an individual has purchased a home or rented an apartment.
Wetzel v. Glen St. Andrew Living Cmty., LLC, 901 F.3d 856, 861
(7th Cir. 2018). And in Bloch, we held that where a unit occu-
pant submits to the rules or regulations of a private entity as
a “condition” of their lease, “§ 3604(b) prohibits [that entity]
from discriminating against [the occupant] through its en-
forcement of the rules, even facially neutral rules.” 587 F.3d at
780.
   A plaintiff may prove discrimination under § 3604 in two
ways: disparate treatment (intentional discrimination) or dis-
parate impact. Id. at 784. The former requires a showing of
discriminatory intent—that the defendant took the action be-
cause of the plaintiff’s protected status. Id. at 783 (“Discrimina-
tory intent is the pivotal element in this case.”). Under a dis-
parate impact theory, however, a plaintiff may bring a claim
under the FHA based on a decision or policy that has a dis-
criminatory effect and no legitimate business or public
No. 24-1532                                                                  7

Other Sections in This Document (43)

Full Text