Cori's Place v. The Zoning Hearing Board of the City of Nanticoke

CourtDistrict Court, M.D. Pennsylvania
DecidedFebruary 2, 2024
Docket3:23-cv-00605
StatusUnknown

This text of Cori's Place v. The Zoning Hearing Board of the City of Nanticoke (Cori's Place v. The Zoning Hearing Board of the City of Nanticoke) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cori's Place v. The Zoning Hearing Board of the City of Nanticoke, (M.D. Pa. 2024).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA

: CORI’S PLACE, : Plaintiff CIVIL ACTION NO. 3:23-CV-605 : v. (JUDGE MANNION) : THE ZONING HEARING BOARD OF THE CITY OF NANTICOKE : and THE CITY OF NANTICOKE, : Defendants :

MEMORANDUM

Plaintiff Cori’s Place brings this action against the City of Nanticoke,1 claiming that it violated the Fair Housing Act and the Americans with Disabilities Act of 1990 when it denied Plaintiff’s zoning permit application. Though that denial has been reversed in state court, Plaintiff asks this court to grant declaratory and monetary relief.

1 Because “[i]t is well established that arms of local municipalities … do not maintain an existence independent from the municipality,” K.S.S. v. Montgomery Cnty. Bd. of Com’rs, 817 F. Supp. 2d 389, 395 (E.D. Pa. 2012), the Zoning Hearing Board of the City of Nanticoke and the City of Nanticoke will be treated as a single Defendant. I. BACKGROUND2 Plaintiff works with adults with intellectual disabilities to promote daily

living skills. It purchased a property in Nanticoke’s “R-2” (Two-Family Residential) Zoning District to use a residence for up to four such individuals. Plaintiff applied for a zoning permit with the Nanticoke Zoning Officer, who

determined that its intended use would require Zoning Hearing Board approval. So Plaintiff applied to the Zoning Hearing Board and a public hearing was held. The Board denied Plaintiff’s application. Plaintiff appealed the Board’s decision to the Luzerne County Court of

Common Pleas, which reversed and ordered that Plaintiff’s application be granted. (Doc. 18-1; Case No. 4830-2021). Plaintiff now claims that Defendant: (Count I) violated the Fair Housing Act by discriminating on the

basis of disability, refusing to make reasonable accommodations, and interfering with FHA rights; and (Count II) violated the Americans with Disabilities Act by discriminating on the basis of disability, excluding individuals with disabilities from publicly-funded services, failing to make

reasonable modifications, and interfering with ADA rights. (Doc. 1 ¶¶37–48).

2 In considering Plaintiff’s Complaint against this Rule 12(b)(6) motion to dismiss, the court must “accept all factual allegations as true, construe the complaint in the light most favorable to the plaintiff, and determine whether, under any reasonable reading of the complaint, the plaintiff may be entitled to relief.” Bruni v. City of Pittsburgh, 824 F.3d 353, 360 (3d Cir. 2016). II. LEGAL STANDARD In response to a complaint, a party may move for dismissal for “failure

to state a claim upon which relief can be granted.” Fed. R. Civ. P. 12(b)(6). To survive dismissal, a complaint must make more than “conclusory or ‘bare- bones’ allegations,” and “‘threadbare recitals of the elements of the cause of

action, supported by mere conclusory statements, do not suffice.’” Fowler v. UPMC Shadyside, 578 F.3d 203, 210 (3d Cir. 2009) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). Instead, the complaint must “set out ‘sufficient factual matter’ to show that the claim is facially plausible.” Id.

(quoting Iqbal, 556 U.S. at 678). In considering the complaint, the court must apply a “two-part analysis.” Id. “First,” the court “must accept all of the complaint’s well-pleaded

facts as true, but may disregard any legal conclusions.” Id. at 210–11. “Second,” the court “must then determine whether the facts alleged in the complaint are sufficient to show that the plaintiff has a plausible claim to relief.” Id. at 211. III. DISCUSSION A. Effect of state court decision

The parties disagree on the effect of the Luzerne County Court of Common Pleas’ decision reversing the Nanticoke Zoning Hearing Board’s denial of Plaintiff’s zoning permit application. (Doc. 18-1).

Plaintiff contends that Defendant is precluded from arguing that it did not violate the Fair Housing Act, because the Court of Common Pleas concluded that it did. (Doc. 18 at 11–12). The Court of Common Pleas made the following conclusions of law.

14. Finally, it should be noted that it is a violation of the FHAA to refuse to make reasonable accommodations in rules, policies, and practices or services when such accommodations may be necessary to afford a person equal opportunity to use and enjoy a dwelling. 42 U.S.C.A. §3604. 15. Subsection (f)(1)(B) specifically states “it shall be unlawful to discriminate in the sale or rental, or to otherwise make unavailable or deny, a dwelling to any buyer or renter because of a handicap of a person residing in or intending to reside in that dwelling after it is so sold, rented, or made available. 42 U.S.C.A. §3601(f)(1)(B). 16. A reasonable accommodation in this case would be to allow the individuals residing at the property to have separate leases, which is currently not allowed under the Ordinance. 17. The individuals who will reside at the property are entitled to such a reasonable accommodation under the FHAA and to deny such accommodation is a violation of federal law designed to protect some of society’s most vulnerable individuals. (Doc. 18-1 ¶¶14–17).3 Under the doctrine of issue preclusion, or collateral estoppel, “once an

issue is actually and necessarily determined by a court of competent jurisdiction, that determination is conclusive in subsequent suits based on a different cause of action involving a party to the prior litigation.” Montana v.

United States, 440 U.S. 147, 153 (1979). “Federal courts must ‘give the same preclusive effect to state court judgments that those judgements would be given in the courts of the State from which the judgments emerged.’” Allegheny Int’l, Inc. v. Allegheny Ludlum Steel Corp., 40 F.3d 1416, 1429 (3d

Cir. 1994) (quoting Kremer v. Chemical Constr. Corp., 456 U.S. 461, 466 (1982)). “The doctrine of collateral estoppel precludes relitigation of an issue

determined in a previous action if: (1) the issue decided in the prior case is identical to the one presented in the later action; (2) there was a final adjudication on the merits; (3) the party against whom the plea is asserted was a party or in privity with a party in the prior case; (4) the party or person

privy to the party against whom the doctrine is asserted had a full and fair opportunity to litigate the issue in the prior proceeding; and (5) the

3 The Fair Housing Amendments Act (FHAA) was “passed in 1988 to extend the coverage of the FHA to include people with disabilities.” Cmty. Servs., Inc. v. Wind Gap Mun. Auth., 421 F.3d 170, 176 (3d Cir. 2005). determination in the prior proceeding was essential to the judgment.” Off. of Disciplinary Couns. v. Kiesewetter, 889 A.2d 47, 50–51 (Pa. 2005).

In state court, Plaintiff appealed the Zoning Hearing Board’s denial of its zoning permit application. (Doc. 18-1 ¶1). The Court of Common Pleas’ scope of review on appeal was “limited to a determination of whether the

board committed an abuse of discretion or a clear error of law.” (Doc. 18-1 at 8 ¶1 (citing Butch v. E. Lackawannock Twp.

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Cori's Place v. The Zoning Hearing Board of the City of Nanticoke, Counsel Stack Legal Research, https://law.counselstack.com/opinion/coris-place-v-the-zoning-hearing-board-of-the-city-of-nanticoke-pamd-2024.