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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On appeal, Farhan maintains that her complaint stated a
claim for discrimination under § 3604(b)—under both a dis-
parate treatment and disparate impact theory—and under
§ 3617. We review the district court’s dismissal under 12(b)(6)
de novo. Brockett, 116 F.4th at 685.
    A. Disparate Treatment
    Farhan argues that her complaint plausibly alleges that
defendants, by enforcing their “neutrality” policy, intention-
ally discriminated against her based on national origin. She
faults the district court for “failing to take all facts set forth in
the complaint as true and all inferences in the light most fa-
vorable” to her.
    But the district court properly observed that her complaint
lacks any allegation relating to a discriminatory intent moti-
vating defendants’ “neutrality” policy. The complaint does
not allege, for example, that the policy only applies to Pales-
tinian flags, as opposed to Israeli flags or other expressive
signage. It does not allege that other non-Palestinian tenants
were able to fly Israeli or Palestinian flags, or that the policy
was only enforced against Palestinian tenants. Indeed, the
complaint strongly implies the opposite, stating that the pol-
icy was “that tenants of Defendants,” with no qualification,
“are required to remain neutral in the so-called ‘Israeli-Pales-
tinian conflict.’” And while the complaint alleges that “other

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