Maine Human Rights Commission v. Megunticook Management

CourtSuperior Court of Maine
DecidedMay 17, 2017
DocketKENcv-15-135
StatusUnpublished

This text of Maine Human Rights Commission v. Megunticook Management (Maine Human Rights Commission v. Megunticook Management) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Maine Human Rights Commission v. Megunticook Management, (Me. Super. Ct. 2017).

Opinion

STATE OF MAINE SUPERIOR COURT KENNEBEC, ss CV-15-135

MAINE HUMAN RIGHTS COMMISSION, SHIRLEY KELDERHOUSE, and SHAUNN PATTON,

Plaintiffs,

v. FINDINGS AND ORDER FOR ENTRY OF JUDGMENT

MEGUNTICOOK MANAGEMENT AND REALTY CORPORATION and JEFFREY WEYMOUTH,

Defendants

Background

This matter came before the Court for trial without a jury on February

21-24, 2017. The Maine Human Rights Commission (MHRC) is represented by Attorney

Barbara Archer-Hirsch. Attorney Patricia Ender represents Ms. Kelderhouse and Mr.

Patton. Attorney Rebecca Webber represents all Defendants. An Amended Complaint

was filed with the Kennebec County Superior Court on September 22, 2015 alleging

three counts: Count 1 against Defendant Megunticook Management and Jeffrey

Weymouth for violation of the Maine Human Rights Act, 5 M .R.S.§4581-A(B)(l)

prohibiting discrimination in housing accommodation based on race; Count II against

1 Rosemary Weymouth for violation of that same statutory provision; and Count III against

all Defendants alleging violation of the Federal Fair Housing Act, 42 U.S.C. §3604(A).

On January 4, 2016 this Court denied Defendant Rosemary Weymouth's Motion to

Dismiss all claims brought against her. On January 26, 2017 the Court granted Ms.

Weymouth's Motion for Summary Judgment for all claims brought against her, but

denied the motion as to other Defendants. The case then proceeded to trial on all three

Counts against Defendants Megunticook Management and Jeffrey Weymouth.

The Court has considered the evidence and exhibits, as well as the parties' written

closing arguments, the last of which were received on March 28, 2017, and issues the

following findings and Order for Entry of Judgment.

Standard of Review

In reviewing claims for discrimination in housing accommodation brought pursuant to

the Maine Human Rights Act and the Federal Fair Housing Act post-trial, the Court applies the

McDonnell Douglas burden-shifting test. In Dussault v. RRE Coach Lantern Holdings, LLC, the

Law Court applied the McDonnell Douglas test to a similar claim for disparate treatment:

When a plaintiff makes a disparate treatment claim ... , a three-step, burden­ shifting test applies. See Daniels v. Narraguagus Bay Health Care Facility, 2012 ME 80, P 14, 45 A.3d 722. First, the plaintiff must establish a prima facie case of discrimination. See id. Second, if the plaintiff has met her burden in the first step, the landlord must present evidence of a legitimate, non-discriminatory reason for the adverse action. See id ~ 15. Third, if the landlord meets its burden in the second step, the plaintiff must present evidence that the landlord's proffered reason is pretextual or untrue. See id. This analysis addresses the parties' burdens of production, not persuasion. [***20] See St. Mary's Honor Ctr. v. Hicks, 509 U.S. 502, 507-08, 521, 113 S. Ct. 2742, 125 L. Ed. 2d 407 (1993).

Dussault v. RRE Coach Lantern Holdings, LLC, 2014 ME 8, ~ 22, 86 A.3d 52.

2 In setting out a prima facie case for discrimination in housing accommodation

pursuant to the Maine Human Rights Act, the plaintiff must show that the defendant who

is a person or agent of a person having the right to sell or rent or manage housing,

unlawfully discriminated against plaintiff by "refus[ing] to show or refus[ing] to sell, rent

lease, let or otherwise deny[ing] to or withhold[ing] from any person the housing

accommodation because of race or color, sex, sexual orientation, physical or mental

disability, religion, ancestry, national origin or familial status". 5 M.R.S. § 4581-A.

According to the federal Fair Housing Act," it shall be unlawful ... [t]o refuse to sell or

rent after the making of a bona fide offer, or to refuse to negotiate for the sale or rental of,

or otherwise make unavailable or deny, a dwelling to any person because of race, color,

religion, sex, familial status, or national origin." 42 U.S.C. § 3604. The Federal Courts

have interpreted the Fair Housing Act broadly, finding that discrimination in the

application process and the denial of the "opportunity to inspect, or even inquire about"

rental housing for discriminatory reasons constitute "discriminatory housing practice[s]".

Gilligan v. Jamco Dev. Corp ., 108 F.3d 246,250 (9th Cir. Cal. 1997).

The Law Court has held that in order to show that the refusal to show or rent or

otherwise deny housing to plaintiff must be "a substantial, even though perhaps not the

only, factor motivating" the defendant. Walsh v. Town ofMillinocket, 2011 ME 99, ,r 25,

28 A.3d 610; citing Wells v. Franklin Broadcasting Corp., 403 A.2d 771, 773 (Me.

1979); Maine Human Rights Comm'n v. City ofAuburn, 408 A.2d 1253, 1268 (Me.

1979). In the analogous employment discrimination case, Wells v. Franklin Broadcasting

Corp., the Law Court held that "even if more than one factor affects the decision to

dismiss an employee, the employee may recover if one factor is his age and in fact it

3 made a difference in determining whether he was to be retained or discharged. If an

employee would not have been dismissed but for his age, the existence of other

reasonable grounds for his discharge does not relieve the employer from liability under

the applicable statutory provisions." Wells, 403 A.2d at 773. Similarly, in a housing

discrimination such as the one before the court, the plaintiff must show that race was a

contributing factor to the defendant's decision not to rent to the plaintiff. See Marano v.

Department ofJustice, 2 F.3d 1137, 1140 (Fed. Cir. 1993) ("The words "a contributing

factor" ... mean any factor which, alone or in connection with other factors, tends to

affect in any way the outcome ofthe decision."). The plaintiff is not required to prove that

race was the only factor in defendant's refusal.

The Federal Courts have adapted the McDonnell Douglas proof standard to

claims brought pursuant to the Fair Housing Act to require a plaintiff to show that "she is

a member of a protected class who applied for and was qualified to rent housing, that she

was rejected, and that the housing opportunity remained available." Gilligan,108 F.3d at

249. The McDonnell Douglas standard governs the burdens of proof, but "it does not

dictate the required elements of a complaint." Id. To that end, where there is no evidence

that a plaintiffs other qualifications for housing were considered by defendant, the court

does not require plaintiff to affirmatively prove that plaintiff is otherwise qualified for

housing. See Id; White v. HUD, 475 F.3d 898, 906 (7th Cir. 2007); Bezi v. Camacho,

2014 U.S. Dist. LEXIS 74047, *28 (C.D. Cal. Mar. 19, 2014) ("even without alleging or

proving financial qualification, a violation of the Fair Housing Act may still have

occurred").

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Related

St. Mary's Honor Center v. Hicks
509 U.S. 502 (Supreme Court, 1993)
Frederick R. Marano v. Department of Justice
2 F.3d 1137 (Federal Circuit, 1993)
Lindsay v. Yates
578 F.3d 407 (Sixth Circuit, 2009)
Lovely v. Allstate Insurance Co.
658 A.2d 1091 (Supreme Judicial Court of Maine, 1995)
Wells v. Franklin Broadcasting Corp.
403 A.2d 771 (Supreme Judicial Court of Maine, 1979)
Maine Human Rights Commission v. City of Auburn
408 A.2d 1253 (Supreme Judicial Court of Maine, 1979)
Daniels v. Narraguagus Bay Health Care Facility
2012 ME 80 (Supreme Judicial Court of Maine, 2012)
Walsh v. Town of Millinocket
2011 ME 99 (Supreme Judicial Court of Maine, 2011)
Nicole Dussault v. RRE Coach Lantern Holdings, LLC
2014 ME 8 (Supreme Judicial Court of Maine, 2014)

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