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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

A Society Without a Name v. Commonwealth of Virginia, 655 F.3d 342 (2011)

Citation
A Society Without a Name v. Commonwealth of Virginia, 655 F.3d 342 (2011)
Parent Document
A Society Without a Name v. Commonwealth of Virginia, 655 F.3d 342 (2011)
Effective Date
2011-08-24

Other Sections in This Document (158)

Full Text

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The Fair Housing Act’s services provision simply
     requires that "such things as garbage collection and
     other services of the kind usually provided by
     municipalities" not be denied on a discriminatory
     basis. [Mackey v. Nationwide Ins. Cos., 724 F.2d
     419, 424 (4th Cir. 1984).] It does not extend to every
     activity having any conceivable effect on neighbor-
     hood residents. See id. (hazard insurance is not a
     "service"); Clifton Terrace Assocs., Ltd. v. United
     Techs. Corp., 929 F.2d 714, 720 (D.C. Cir. 1991)
     (elevator manufacturer is not a provider of "ser-
     vices"); Southend Neighborhood Improvement Ass’n
     [v. St. Clair County, 743 F.2d 1207, 1210 (7th Cir.
     1984)] (maintenance of county-owned neighborhood
     property is not a "service"); Laramore v. Illinois
     Sports Facilities Auth., 722 F. Supp. 443, 452 (N.D.
     Ill. 1989) (stadium site selection is not the provision
     of a "service"). "To say that every discriminatory
     municipal policy is prohibited by the Fair Housing
     Act would be to expand that Act to a civil rights stat-
     ute of general applicability rather than one dealing
     with the specific problems of fair housing opportuni-
     ties." Clifton Terrace Assocs., 929 F.2d at 720 (quot-
     ing Vercher v. Harrisburg Housing Auth., 454 F.
     Supp. 423, 424 (M.D. Pa. 1978)).