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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that holds together.” Id. at 404. Applied to the facts at issue,
we found that Swanson’s FHA claim met this stand-
ard: “Swanson’s complaint identifies the type of discrimina-
tion that she thinks occurs (racial), by whom (Citibank … ),
and when (in connection with her effort in early 2009 to obtain
a home-equity loan). This is all that she needed to put in the
complaint.” Id. at 405.
   Farhan’s allegations clear the Swanson threshold. Her com-
plaint identifies the “type of discrimination that she thinks oc-
cur[red]” (national origin); “by whom” (Defendants); “and
when” (in connection with Defendants’ eviction of her after
she refused to remove a Palestinian flag from her window fol-
lowing the October 2023 escalation of conflict between Israel
and Palestine). Id. Granted, the facts she pleads, even taken as
true, do not conclusively show Defendants violated the FHA.
But they don’t need to. Her allegations, theory of the case, and
the reasonable inferences therefrom make her claim of dis-
crimination plausible. That’s enough to survive a motion to
dismiss. Iqbal, 556 U.S. at 678.
                               II
    My colleagues see things differently. They conclude Far-
han hasn’t pleaded facts showing Defendants’ neutrality pol-
icy regarding the Israeli–Palestinian conflict was created and
applied to Farhan because of her national origin. The majority
draws this test from Bloch v. Frischholz, where we held that a
challenge to a homeowners’ association policy that prohibited
displaying objects outside of unit doors survived summary
judgment. 587 F.3d 771, 785 (7th Cir. 2009) (en banc). Because
a reasonable jury could conclude the association “reinter-
preted” the preexisting policy “to apply to [plaintiffs] ‘be-
cause of’ and not merely ‘in spite of’” their Jewish faith, we
No. 24-1532                                                       21

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