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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Quigley v. Winter, 598 F.3d 938 (2010)

Citation
Quigley v. Winter, 598 F.3d 938 (2010) 2.
Parent Document
Quigley v. Winter, 598 F.3d 938 (2010)
Effective Date
2010-03-16

Other Sections in This Document (232)

Full Text

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2.     Hostile Housing Environment Created by Sexual Harassment
       As a preliminary matter, Winter questions whether a claim for hostile housing
environment created by sexual harassment is actionable under the FHA. We conclude
it is. See Neudecker v. Boisclair Corp., 351 F.3d 361, 364 (8th Cir. 2003)
(recognizing a cause of action under the FHA for hostile housing environment created
by disability harassment and citing, with approval, cases from other jurisdictions
recognizing an FHA claim for hostile housing environment created by sexual
harassment); see also DiCenso v. Cisneros, 96 F.3d 1004, 1008 (7th Cir. 1996)
(recognizing an FHA claim for hostile housing environment created by sexual
harassment); Honce v. Vigil, 1 F.3d 1085, 1089-90 (10th Cir. 1993) (same).4