The Ohio House, LLC v. City of Costa Mesa, 135 F.4th 645 (2024)

Citation: The Ohio House, LLC v. City of Costa Mesa, 135 F.4th 645 (2024)
Parent Document: The Ohio House, LLC v. City of Costa Mesa, 135 F.4th 645 (2024)
Jurisdiction: United States (federal)
Effective Date: 2024-12-04
Original Source: https://www.courtlistener.com/opinion/10287865/the-ohio-house-llc-v-city-of-c... ↗

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violated the FHA’s and the FEHA’s prohibition against
discriminatory statements by enacting a facially
discriminatory zoning code fails for the same reasons that
the disparate treatment claim fails. Comments made by
individual city employees suggesting that they had a
discriminatory purpose for adopting the challenged zoning
regulations are, standing alone, insufficient to overturn the
jury’s verdict.
    The panel affirmed the district court’s denial of judgment
as a matter of law on Ohio House’s claim that the City
interfered with Ohio House aiding or encouraging others’
exercise of their rights under the FHA because Ohio House
failed to prove a causal link between its protected activity of
providing sober-living housing and the City’s actions that
impeded that activity. The panel adopted the Seventh
Circuit’s approach to causation, which requires proof of
intentional discrimination or discriminatory animus to
establish a prima facie claim based on an interference theory.
    The panel affirmed the district court’s denial of judgment
as a matter of law on Ohio House’s facial challenge to the
City’s reasonable-accommodation ordinance, concluding
that (1) the City’s reasonable-accommodations ordinance is
not facially inconsistent with the FHA; and (2) the jury had
an evidentiary basis for finding that Ohio House’s requested
accommodation—granting an exception to the separation
requirement—was unreasonable. Because the jury
ultimately reached the correct outcome, it was harmless error
for the district court to submit this purely legal issue to the
jury.
   Finally, the panel affirmed the district court’s denial of
Ohio House’s post-trial renewed motion for judgment as a
          THE OHIO HOUSE, LLC V. CITY OF COSTA MESA         5

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