Fair Housing Justice Center, Inc. v. 203 Jay St. Associates, LLC

CourtDistrict Court, E.D. New York
DecidedAugust 4, 2022
Docket1:21-cv-01192
StatusUnknown

This text of Fair Housing Justice Center, Inc. v. 203 Jay St. Associates, LLC (Fair Housing Justice Center, Inc. v. 203 Jay St. Associates, LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fair Housing Justice Center, Inc. v. 203 Jay St. Associates, LLC, (E.D.N.Y. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK FAIR HOUSING JUSTICE CENTER, INC., Plaintiff, MEMORANDUM & ORDER against: 21-CV-1192 (NGG) (JRC) 203 JAY ST. ASSOCIATES, LLC, AMTRUST REALTY CORP., AND WOODS BAGOT ARCHITECTS, P.C., Defendants,

NIGHOLAS G, GARAUFIS, United States District Judge. Pending before the court are Defendants 203 Jay Street Associ- ates, LLC, Amstrust Realty Corp., and Woods Bagot Architects, P.C.’s motions to dismiss. For the reasons set forth below, the motions are DENIED. : I, BACKGROUND A. Factual Background The following summary is drawn from the facts alleged in the Amended Complaint, which the court accepts as true. See N.Y. Pet Welfare Ass’n v. City of N.Y., 850 F.3d 79, 86 (2d, Cir. 2017). 1. The Parties Fair Housing Justice Genter, Inc. (“Plaintiff’ or “FHJC”) “is a non- profit organization dedicated to ensuring that all people have equal access to housing opportunities in the New York City met- ropolitan region.” (Am. Compl. (Dkt. 15) § 14.) In furtherance of this mission, Plaintiff provides counseling, legal referrals, and other services to individuals who have experienced housing dis- crimination. (See id. at 416.) Additionally, Plaintiff conducts investigations into housing discrimination. (See id.) In the course of these investigations, Plaintiffs employees “assume the role of

renters or homebuyers for the purpose of obtaining information about ... whether housing discrimination is taking place.” (Id. at { 18.) In other words, the employees act as “testers” of the alleg- edly discriminatory condition. Defendant 203 Jay St. Associates, LLC (“203 Jay”) is a New York domestic limited liability company. (See id. at { 25). Defendant Amitrust Realty Corp. (“Amtrust”) is a New York domestic busi- ness corporation. (See id. at {26}. These Defendants own the property referred to as the 203 Jay Street Condominium (the “Condominium”), located at 120 Nassau Street in Kings County, New York. (See id. at §] 7-8, 23-24; 203 Jay & Amtrust Mem. in Supp. of Mot. to Dismiss (“203 Jay Mot,”) (Dkt. 22) at 2.) Dax fendant Woods Bagot Architects, P.C. (“Woods Bagot”), a New York Professional Corporation, designed the Condominium. (See Am. Compl. 934-35; 203 Jay Mot. at 2.) □

2. The Investigation This suit arises out of a series of investigations into the Condo- minium. (See Am. Compl. 939.) Plaintiff sent two testers to inquire about apartments on behalf of a wheelchair-bound rela- tive. (See id. § 43.) The testers were shown four apartments where they allegedly observed, among other things, heavy doors -at the entrance to the building; narrow interior doors in the apartments; narrow kitchens; insufficient clear floor space in the bathrooms of certain apartments; and bathrooms with one-inch beveled thresholds. (See id. §44.)! Plaintiff subsequently sent two additional testers to similarly inquire about apartments on behalf of a wheelchair-bound relative. (See id. 445.) These test- ers made similar observations regarding the building and the apartments they were shown. (See id. { 46.) Plaintiff also sent a consulting accessibility expert to the property. (See id. {47.) The

1A beveled threshold is a door threshold with an incline that enables greater access for wheelchair users.

expert observed various defects in the building’s accessibility in- cluding, but not limited to, a lack of accessible seating in the lounge on the building’s 33rd floor and an excessively sloped route from the public sidewalk to the lobby on Concord Street. (See id. 4 48.) B. Procedural Background Plaintiff filed its complaint on March 5, 2021. (See Compl. (Dkt. 1).) Following a July 27, 2021 pre-motion conference, Plaintiff filed the Amended Complaint on August 8, 2021. Plaintiff asserts claims under the Fair Housing Act (“FHA”), 42 U.S.C. §§ 3601 et seq.; the New York State Human Rights Law, Article 15 of the New York State Executive Law; the New York City Human Rights Law, N.Y.C. Admin. Code § 8-107 et seq.; and the New York State Civil Rights Law § 40 et seq., arising out of Defendants’ failure to design and construct housing accessible to disabled individuals. Plaintiff seeks declaratory relief, compensatory and punitive damages, and a permanent injunction ordering Defendants to re- move all violations of the aforementioned laws and to refrain from further discrimination on the basis of disability. Defendants filed separate motions to dismiss pursuant to Rules 12(b)(1) and 12(b)(6) of the Federal Rules of Civil Procedure. Defendants assert that Plaintiff lacks standing and has failed to state a claim for relief. Defendant Woods Bagot further argues that Plaintiffs request for injunctive relief is inappropriate as to Woods Bagot and must be denied. Ii. STANDING □ A. Article I Standing 1. Legal Standard The United States Constitution “confines the federal judi- cial power to the resolution of ‘Cases’ and ‘Controversies.”

TransUnion LLC v. Ramirez, 141 S, Ct. 2190, 2203 (2021). If there is no case or controversy, a federal court lacks subject mat- ter jurisdiction to hear a dispute, and the action must be dismissed. See Fed. R. Civ. P. 12(h)(3). To establish that the court . has subject matter jurisdiction over a dispute, a plaintiff must sat- isfy Article III standing. See Transunion, 141 S. Ct. at 2203. The party “invoking the authority of the court bears the burden of proof on the issue of standing.” Lee v. Bd. of Governors of the Fed. Reserve Sys., 118 F.3d 905, 910 (2d Cir. 1997). This means that a plaintiff must show (i) a concrete, particularized, and actual or □ imminent injury in fact (ii) that is fairly traceable to the defend- ant and (iii) which would be redressed by a favorable judicial decision. See Lujan v. Defs. of Wildlife, 504 U.S. 555, 560-61 (1992). An organization may establish standing by bringing claims on be- half of its members (“associational standing”) or by demonstrating that the organization itself has suffered an injury for which it seeks judicial redress (“organizational standing”). See N.Y. Civil Liberties Union v. N.Y.C. Transit Auth., 684 F.3d 286, 294 (2d Cir. 2012). To establish associational standing, an or- ganization must “allege that its members, or any one of them, are suffering immediate or threatened injury as a result of the chal- lenged action of the sort that would make out a justiciable case had the members themselves brought suit.” Warth v. Seldin, 422 U.S. 490, 511 (1975). By contrast, to establish organizational standing, an organization need demonstrate only that “it can in- dependently satisfy the requirements of Article II] standing.” Nnebe v. Daus, 644 F.3d 147, 156 (2d Cir. 2011). “Under this theory of ‘organizational’ standing, the organization is just an- other person—albeit a legal person—seeking to vindicate a right.” N.Y. Civil Liberties Union, 684 F.3d at 294.

2 When quoting cases, and unless otherwise noted, all citations and quota- tion marks are omitted, and all alterations are adopted.

2. Discussion Plaintiff “brings suit here under a theory of organizational stand- ing, not one of associational standing.” (Pl.’s Mem. in Opp. (“Opp.”) (Dkt.

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Fair Housing Justice Center, Inc. v. 203 Jay St. Associates, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fair-housing-justice-center-inc-v-203-jay-st-associates-llc-nyed-2022.