Des Moines Civil and Human Rights Commission v. Patrick Knueven and Mary Knueven

CourtSupreme Court of Iowa
DecidedApril 7, 2023
Docket21-1092
StatusPublished

This text of Des Moines Civil and Human Rights Commission v. Patrick Knueven and Mary Knueven (Des Moines Civil and Human Rights Commission v. Patrick Knueven and Mary Knueven) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Des Moines Civil and Human Rights Commission v. Patrick Knueven and Mary Knueven, (iowa 2023).

Opinion

IN THE SUPREME COURT OF IOWA

No. 21–1092

Submitted February 21, 2023—Filed April 7, 2023

DES MOINES CIVIL AND HUMAN RIGHTS COMMISSION,

Appellee,

vs.

PATRICK KNUEVEN and MARY KNUEVEN,

Appellants.

Appeal from the Iowa District Court for Polk County, Sarah Crane, Judge.

A landlord appeals the district court judgment against him for housing

discrimination based on religion or national origin. REVERSED AND

REMANDED.

Christensen, C.J., delivered the opinion of the court, in which all justices

joined.

John F. Fatino (argued) and Nicholas J. Gral of Whitfield & Eddy, P.L.C.,

Des Moines, for appellants.

Luke DeSmet (argued) and Michelle Mackel-Wiederanders, Assistant City

Attorneys, for appellee. 2

CHRISTENSEN, Chief Justice.

The Des Moines Civil and Human Rights Commission alleged the

defendants, a husband and wife who own rental properties together,

discriminated against prospective tenants in violation of municipal law by

steering prospective tenants of a protected religion or national origin away from

their rental properties. A jury found only the husband liable and imposed a

penalty against him for $50,000. He appealed and raises several issues, ranging

from challenges to the district court’s evidentiary rulings to the jury instructions

on the elements of steering and the sufficiency of the evidence to submit the

claim of steering to the jury. Both husband and wife challenge the district court

attorney fee award to the Commission.

On our review, we reverse the district court judgment. The district court

incorrectly instructed the jury that steering occurs merely by “discouraging” a

member of a protected class from pursuing housing and “encouraging” a member

not of the protected class. Such an instruction exposed the defendants to liability

for conduct not prohibited by the Iowa Civil Rights Act or the relevant Des Moines

ordinance. There is insufficient evidence against the defendants under the

proper jury instruction. Accordingly, we reverse the district court judgment,

vacate the award of attorney fees to the Commission, and remand for dismissal

of the steering charge against Patrick and a determination of whether Patrick

should be awarded attorney fees as the now prevailing party. 3

I. Background Facts and Proceedings.

Patrick and Mary Knueven are a married couple who own various rental

properties in the Des Moines area that Patrick rents to tenants while operating

as the landlord. They came to the attention of the Des Moines Civil and Human

Rights Commission (Commission) when an individual filed a complaint alleging

that Patrick had engaged in housing discrimination in 2015. Upon further

review, the Commission chose to investigate the complaint through the use of

housing testers to gauge whether Patrick was participating in some type of

discriminatory housing practice.

Joshua Barr, the Commission’s director, explained:

Housing testers are persons who go in and try to rent a property, et cetera, and they determine how they are treated and typically have two types: It’s the control which is typically someone that’s of European descent or white, as others may say, and then we have someone of another [protected] characteristic . . . [such as] someone of a different skin color.

The Commission conducted this testing over the course of a few months in 2015

and 2016 and then again later in 2017.

A. 2015–16 Testing. On December 22, 2015, Chris Fultz, a white male

acting as a control tester, called Patrick to schedule an in-person tour of the

Knuevens’ Porter Avenue rental property. Fultz met with Patrick at the rental

property the next day, which Fultz described as a “relatively uneventful” visit

that involved Patrick walking him through the property. There is no recording of

the phone call or visit in the record.

On December 28, Deeq Abdi, a protected tester, called Patrick to inquire

about the same property in a recorded call. Abdi has an accent that indicates he 4

is not a native English speaker. During the call, Abdi told Patrick his name and

noted that he was calling to see if the rental property was available. Patrick

responded, “It’s rented. It’s taken and they’re living there.” When Abdi asked who

he was speaking to, Patrick said his name was “Joe.” Abdi asked if any other

units would be coming available, and Patrick answered, “Nope.” Abdi thanked

Patrick, and Patrick ended the call without a response. Overall, Abdi described

Patrick as evasive, explaining that Patrick avoided his questions and gave him

the impression “that he doesn’t want to rent the apartment to me because [for]

no reason [he] was trying to cut me off and you can see that.”

Fultz called Patrick again on January 4, 2016, about the rental property

at issue. After Patrick informed him that he rented the property to someone else,

Fultz asked if Patrick had anything else available to rent. Patrick told him that

he had a different property that would be available in a week. There is no

recording of this call in the record.

The Commission conducted similar testing during that time period

involving two females: one a white control tester and the other a Muslim

protected tester. The control tester, Jodi Mashek, spoke with Patrick over the

phone on January 27 about a different rental property and arranged an

in-person visit. That visit occurred on January 29. She reported that Patrick gave

her a tour of the property, answering any questions she had and pointing out

new appliances and flooring. He also mentioned that “it was a really nice

neighborhood, [and] that neighbors on both sides had been there for a very long

time.” There is no recording of this call or visit in the record. 5

The protected tester, Nadia Ingram, first interacted with Patrick over the

phone on January 28 in a recorded call that does not reveal any of her protected

characteristics. Patrick asked her a few questions about when she was looking

to move in and arranged for Ingram to view the property with him the next day.

Ingram arrived for the visit wearing a hijab, which she describes as a “head scarf”

that “easily identifie[s]” her as Muslim, with her two young children in tow. She

discreetly captured an audio recording of her visit.

Ingram testified that Patrick “didn’t really say hi when I initially said hi.”

He immediately asked her if her husband was with them and “seemed a little

disappointed” that she did not bring her husband. Ingram described Patrick as

“tense,” explaining,

[E]very time I walked into a room, [Patrick] walked out. It seems like he didn’t want to be around me. I also noticed a lot of times when he would be leaving a room, he would be muttering expletives under his breath not loud enough that he wanted me to hear it but I could certainly hear what he was saying.

When she asked Patrick what the neighborhood was like, he claimed he didn’t

know about the neighborhood or what the neighbors were like.

Ingram summarized the differences in her experience with Patrick over the

phone when he was unaware of her protected status compared to her subsequent

in-person visit when she was identifiable as Muslim. She testified,

On the phone, like I said before, he was polite, he was asking lots of questions about our situation, when we were looking to move.

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