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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at 806). They are required only to make reasonable
accommodations.          Id.   “[A]n     accommodation         is
reasonable . . . ‘when it imposes no “fundamental alteration
in the nature of the program” or “undue financial or
administrative burdens.”’” Giebeler, 343 F.3d at 1157
(quoting Howard v. City of Beavercreek, 276 F.3d 802, 806
(6th Cir. 2002)). Recognizing the case-specific nature of a
reasonable-accommodation analysis, FHA regulations
intentionally provide little guidance on how to determine the
reasonableness of an accommodation or the need for a
particular rule in a zoning scheme. See Schwarz v. City of
Treasure Island, 544 F.3d 1201, 1220 n.12 (11th Cir. 2008)
(first citing 42 U.S.C. § 3610(g)(2)(C); and then citing Fair
Housing Amendments Act of 1988, 54 Fed. Reg. 3232, 3246
(Jan. 23, 1989)); see also Oconomowoc Residential
Programs v. City of Milwaukee, 300 F.3d 775, 784 (7th Cir.
2002) (“Whether a requested accommodation is reasonable
or not . . . requires balancing the needs of the parties.”). The
Eleventh Circuit’s survey of the caselaw from the Supreme
Court and our sister circuits in Schwarz v. City of Treasure
Island provides helpful guidance:

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