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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

§ 290

Citation
§ 290
Parent Document
Francis v. Kings Park Manor, Inc., 992 F.3d 67 (2021)
Effective Date
2021-03-25

Other Sections in This Document (993)

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12 The majority casts Wetzel, in which the Seventh Circuit held that a landlord could be
liable for tenant-on-tenant harassment, as a case involving an “unusual degree of
control” over a community of senior citizens. Majority Op. at 24–25. But Wetzel
addressed the landlord-tenant relationship generally, while explicitly “say[ing]
nothing” about the FHA’s application to “a skilled nursing facility[] or an assisted living
environment,” each of which is “different enough that they should be saved for another
day.” Wetzel, 901 F.3d at 864.
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policy concern ahead of a legal mandate. See Bostock v. Clayton Cnty.,