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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JACKSON-AKIWUMI, Circuit Judge, dissenting. There is no
heightened pleading standard for discrimination claims. See
Swierkiewicz v. Sorema N. A., 534 U.S. 506, 511–12 (2002);
Thomas v. JBS Green Bay, Inc., 120 F.4th 1335, 1337–38 (7th Cir.
2024). The routine pleading standard applicable to such cases
requires “a short and plain statement of the claim showing
that the pleader is entitled to relief.” FED. R. CIV. P. 8(a)(2).
“Specific facts are not necessary.” Erickson v. Pardus, 551 U.S.
89, 93 (2007). Plaintiffs need only plead facts showing that the
claim is “plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662,
678 (2009).
    Manal Farhan clears this low bar. She alleges facts that al-
low the plausible inference that the owner and operator of her
apartment building (“Defendants”) violated the Fair Housing
Act (“FHA”), 42 U.S.C. § 3601 et seq., by discriminating against
her because of her Palestinian national origin. But in affirming
the district court’s dismissal of Farhan’s complaint under Fed-
eral Rule of Civil Procedure 12(b)(6), the majority imposes ad-
ditional pleading hurdles that our case law does not support
and fails to draw all reasonable inferences in Farhan’s favor. I
respectfully dissent.
                                I
   We explained how the pleading standard outlined above
applies to FHA claims in Swanson v. Citibank, N.A., 614 F.3d
400 (7th Cir. 2010). There, the district court had dismissed
Swanson’s claim that Citibank discriminated against her on
the basis of race when the bank denied her application for a
home loan. Id. at 402–03, 407. We reversed, explaining that to
meet the plausibility standard required by Rule 8 of the Fed-
eral Rules of Civil Procedure, a “plaintiff must give enough
details about the subject-matter of the case to present a story
20                                                  No. 24-1532

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