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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Accordingly, we affirm the district court’s denial of Ohio
House’s renewed motion for judgment as a matter of law on
its interference claim.
             5. Reasonable Accommodation
    Below, Ohio House raised a facial challenge to the City’s
reasonable-accommodation ordinance, see CMMC §§ 13-
200.60 to 13-200.63, argued that it was unlawfully denied an
accommodation, and moved for summary judgment on this
claim. Ohio House correctly notes that the district court
failed to decide the purely legal issue presented by Ohio
House’s facial challenge and instead submitted the entirety
of the reasonable-accommodation claim to the jury.
Nonetheless, again, it was harmless error to submit this
claim to the jury if the jury ultimately reached the correct
outcome. Minneapolis & Saint Louis Ry. Co., 119 U.S. at
152.
    After the jury found that the City did not “unlawfully
refuse to make a reasonable accommodation,” the district
court denied Ohio House’s motion for judgment as a matter
of law. It concluded that the jury lawfully could have found
that the requested accommodation was unreasonable
because it was unnecessary for disabled individuals to be
able to reside in the dwelling of their choosing and because
46         THE OHIO HOUSE, LLC V. CITY OF COSTA MESA

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