Michel-Wiggins v. Jes Holdings LLC

CourtDistrict Court, E.D. Missouri
DecidedMay 27, 2025
Docket4:24-cv-01487
StatusUnknown

This text of Michel-Wiggins v. Jes Holdings LLC (Michel-Wiggins v. Jes Holdings LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michel-Wiggins v. Jes Holdings LLC, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

MIRLANDE DINA ) MICHEL-WIGGINS, ) ) Plaintiff, ) ) vs. ) Case No. 4:24 CV 1487 CDP ) JES HOLDINGS, LLC, et al., ) ) Defendants. )

MEMORANDUM AND ORDER

This matter is before the Court on defendants’ motion to dismiss plaintiff’s complaint under Federal Rule of Civil Procedure 12(b)(6). ECF 17. Plaintiff, a self-represented litigant, opposes the motion to dismiss. ECF 22. Defendants filed a reply brief in support of dismissal and the issues are fully briefed. Plaintiff’s complaint is dismissed for the reasons set forth below. Background Plaintiff alleges that she is disabled and applied for an apartment at Havenwood Gardens II in Georgia using a housing voucher. Havenwood is alleged to be owned and managed by defendants Jes Holdings and Fairway Management. Plaintiff alleges that defendants committed housing discrimination under the Fair Housing Amendments Act of 1988 (“the Fair Housing Act” or “FHA”),see 42 U.S.C. § 3604, by failing and refusing to rent her two apartments under her single housing voucher.1 Plaintiff alleges that she needs two apartments under a single housing voucher to accommodate a live-in aide.2 Plaintiff also

alleges that defendants discriminated against her because they have not agreed to pick up her trash and deliver her mail to her front door as a reasonable accommodation to her disability. Plaintiff requests the Court “order defendants to

give her a quote for a second unit and the second unit under one lease (to include my main unit), so I could use my HUD voucher.” ECF 1 at 5. She admits this is “for the purpose of being able to subsidize both units under Plaintiff’s HUD House Choice Voucher (also known as Section 8).” ECF 1-1 at 1. She also asks the

Court to order defendants to pick up her trash and either deliver her mail to her front door or put a mailbox outside her door. ECF 1.

1 Although not alleged in the complaint, in opposition to dismissal plaintiff argues that the defendants also violated the Rehabilitation Act, which provides that “[n]o otherwise qualified individual with a disability . . . shall, solely by reason of her or his disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance . . . .” 29 U.S.C. § 794. Plaintiff cannot amend her complaint by citing statutes in opposition to dismissal that have not been pleaded in her complaint. However, because courts have found that the requirements for a “reasonable accommodation” are the same under the Fair Housing Act and the Rehabilitation Act, see Developmental Services of NE v. City of Lincoln, 504 F. Supp. 2d 714, 723 (D. Neb. 2007) (citing cases), even if properly pleaded any Rehabilitation Act claims would fail for the reasons explained below.

2 Plaintiff asserts that her past experience with caregivers precludes her from sharing an apartment with a live-in aide. Legal Standard The purpose of a motion to dismiss under Rule 12(b)(6) is to test the legal

sufficiency of the complaint. In ruling on such a motion, I must accept all factual allegations in the complaint as true and view them in the light most favorable to the plaintiff. Hager v. Arkansas Dept. of Health, 735 F.3d 1009, 1013 (8th Cir. 2013).

To survive a motion to dismiss, a complaint must contain enough facts “to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 657 (2007) (cleaned up). A claim is facially plausible where the facts allow the court to draw the “reasonable inference that the defendant is liable for the misconduct

alleged.” Id. Absent adequate factual support, the Court “is not required to divine the litigant’s intent and create claims that are not clearly raised, and it need not conjure up unpled allegations to save a complaint.” Gregory v. Dillard’s, Inc., 565

F.3d 464, 473 (8th Cir. 2009) (cleaned up). Discussion The Fair Housing Act prohibits discrimination based on disability against any person with respect to the rental of a dwelling or the provision of related

services or facilities. See 42 U.S.C. § 3604(f)(1) and (2). Discrimination under the FHA includes “a refusal to make reasonable accommodations in rules, policies, practices, or services, when such accommodations may be necessary to afford such

person equal opportunity to use and enjoy a dwelling.” 42 U.S.C. § 3604(f)(3)(B). An accommodation is unreasonable if it imposes an undue financial burden. One Love Housing, LLC v. City of Anoka, Minnesota, 93 F.4th 424, 429-30 (8th Cir.

2024). The Fair Housing Act does not “encompass an obligation to accommodate a tenant’s shortage of money.” Klossner v. IADU Table Mound MHP, LLC, 65 F.4th 349, 354 (8th Cir. 2023) (cleaned up).

Plaintiff’s complaint fails to state a claim of housing discrimination because defendants are not required to provide plaintiff two apartments for a single housing voucher as a reasonable accommodation to her disability. That plaintiff may have legitimate reasons for desiring to live separately from her live-in aide, see ECF 6,

does not mean that defendants are required to accommodate those reasons by renting her two apartments under a single housing voucher and lease.3 Plaintiff’s requested accommodation is not reasonable on its face as it would

impose an undue financial burden on defendants by requiring them to rent two apartments for only one housing voucher. HUD and the local public housing authorities (“PHAs”) control the rent that a landlord may receive for a Section 8 apartment. The PHA issues a tenant a voucher for a fixed amount “equal to the

lower of (1) the payment standard for the family minus the total tenant payment; or

3 Plaintiff failed to allege that a live-in aide was approved by the public housing authority (in this case the Georgia Department of Community Affairs), which is required by HUD regulations. See 24 C.F.R. § 982.316(a). Plaintiff’s allegation that she provided defendants with “documentation from her health care provider which verified Plaintiff’s need for a live-in aide” does not plausibly allege that the housing authority approved a live-in aide. (2) the gross rent minus the total tenant payment.” 24 C.F.R. § 982.505(b). The “payment standard for the family is the lower of (i) the payment standard amount

for the family unit size; or (ii) the payment standard amount for the size of the dwelling unit rented by the family.” 24 C.F.R. § 982.505(c).

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Related

Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Gregory v. Dillard's, Inc.
565 F.3d 464 (Eighth Circuit, 2009)
DEVELOPMENTAL SERVICES OF NE v. City of Lincoln
504 F. Supp. 2d 714 (D. Nebraska, 2007)
Barbara Hager v. Arkansas Dept. of Health
735 F.3d 1009 (Eighth Circuit, 2013)
Suellen Klossner v. IADU Table Mound MHP, LLC
65 F.4th 349 (Eighth Circuit, 2023)
One Love Housing, LLC v. City of Anoka, MN
93 F.4th 424 (Eighth Circuit, 2024)

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Bluebook (online)
Michel-Wiggins v. Jes Holdings LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michel-wiggins-v-jes-holdings-llc-moed-2025.