(PS) Faruki v. Housing Authority for the County of Sacramento

CourtDistrict Court, E.D. California
DecidedApril 28, 2025
Docket2:25-cv-00507
StatusUnknown

This text of (PS) Faruki v. Housing Authority for the County of Sacramento ((PS) Faruki v. Housing Authority for the County of Sacramento) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
(PS) Faruki v. Housing Authority for the County of Sacramento, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 MEKAL FARUKI, No. 2:25-cv-0507-DJC-CKD (PS) 12 Plaintiff, 13 v. ORDER 14 HOUSING AUTHORITY FOR THE 15 COUNTY OF SACRAMENTO, et al., 16 Defendants.

17 18 Plaintiff Mekal Faruki proceeds without counsel1 and alleges housing discrimination by 19 public housing authorities. Plaintiff’s request to proceed in forma pauperis makes the showing 20 required by 28 U.S.C. § 1915. (ECF No. 2.) Plaintiff’s request to proceed in forma pauperis is 21 granted. However, the complaint fails to state a claim and must be dismissed. Plaintiff is granted 22 leave to file an amended complaint within 30 days of the date of this order. 23 I. Screening Requirement 24 Pursuant to 28 U.S.C. § 1915(e), the court must screen every in forma pauperis 25 proceeding, and must order dismissal of the case if it is “frivolous or malicious,” “fails to state a 26 claim on which relief may be granted,” or “seeks monetary relief against a defendant who is 27 1 Because plaintiff proceeds without counsel, this action is referred to the undersigned by Local 28 Rule 302(c)(21) pursuant to 28 U.S.C. § 636. 1 immune from such relief.” 28 U.S.C. § 1915(e)(2)(B); Lopez v. Smith, 203 F.3d 1122, 1126-27 2 (2000). In performing this screening, the court liberally construes a pro se plaintiff’s pleadings. 3 See Eldridge v. Block, 832 F.2d 1132, 1137 (9th Cir. 1987). 4 A complaint must contain “a short and plain statement of the claim showing that the 5 pleader is entitled to relief....” Fed. R. Civ. P. 8(a)(2). Detailed factual allegations are not 6 required, but “[t]hreadbare recitals of the elements of a cause of action, supported by mere 7 conclusory statements, do not suffice[.]” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Bell 8 Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)). While factual allegations are accepted as 9 true, legal conclusions are not. Iqbal, 556 U.S. at 678. Courts “are not required to indulge 10 unwarranted inferences[.]” Doe I v. Wal-Mart Stores, Inc., 572 F.3d 677, 681 (9th Cir. 2009) 11 (internal quotation marks and citation omitted). 12 Pro se litigants are entitled to have their pleadings liberally construed and to have any 13 doubt resolved in their favor, Eldridge, 832 F.2d at 1137, but a plaintiff’s claims must be facially 14 plausible to survive screening. Facial plausibility for a claim requires sufficient factual detail to 15 allow the court to reasonably infer that a named defendant is liable for the misconduct alleged. 16 Iqbal, 556 U.S. at 678. 17 II. Plaintiff’s Allegations 18 Plaintiff is elderly and “a qualified individual with a disability” who was [u]ndergoing 19 cancer chemotherapy and suffering its severe side effects, including extreme fatigue, cognitive 20 impairment, neuropathy and physical weakness.” (ECF No. 1 at 2, 7.) Defendants are public 21 housing authorities responsible for administering Section 8 Housing Choice Vouchers. (Id. at 2.) 22 Plaintiff applied for and met all eligibility requirements for a Section 8 Housing Choice Voucher, 23 but “[o]ver the course of 90 incidents, Defendants denied, delayed, or failed to process Plaintiff’s 24 Section 8 voucher application and renewal requests, solely based on Plaintiff’s disability and 25 elder status.” (Id.) 26 Defendants engaged in a pattern and practice of systemic discrimination, including 27 refusing to grant a reasonable accommodation for expedited processing of plaintiff’s voucher, 28 deliberately delaying the application process while approving non-disabled applicants, providing 1 false or misleading information about voucher availability and plaintiff’s eligibility, and failing to 2 make necessary policy modifications in violation of federal and state law. (ECF No. 1 at 2.) 3 Plaintiff actively pursued his claims but “defendants continued to deny assistance[.]” (Id.) 4 Defendants’ misconduct included “90 instances of denying Section 8 vouchers[.]” (Id. at 3.) 5 Plaintiff brings five causes of action as follows: (1) Violations of the ADA (42 U.S.C. § 6 12101 et seq.); (2) Violations of the FHA (42 U.S.C. § 3601 et seq.; (3) Violations of the Unruh 7 Civil Rights Act (Cal. Civ. Code § 51); (4) Violation of California Disabled Persons Act 8 (“CDPA”) (Cal. Civ. Code § 54); and (5) Fraud (Cal. Civ. Code § 1708). (ECF No. 1 at 3-4.) 9 Plaintiff seeks damages and injunctive relief. (Id. at 4.) 10 III. Discussion 11 The complaint contains many generalized statements and conclusions but is short on 12 factual allegations describing specifically how defendants discriminated against plaintiff, denied 13 plaintiff assistance, or denied a reasonable accommodation. The complaint mostly contains 14 conclusions that defendants subjected plaintiff to housing discrimination. However, general 15 allegations that defendants deliberately delayed or denied plaintiff assistance, provided false or 16 misleading information, and engaged in “90 instances” of misconduct are too vague to state a 17 claim for relief. Conclusory allegations like these do not give fair notice of the claims. See Iqbal, 18 556 U.S. at 678. 19 Having performed the screening required by 28 U.S.C. § 1915, the court finds plaintiff 20 fails to state a claim under the ADA or the FHA. Plaintiff will have an opportunity to amend. 21 Below, the court sets forth legal standards governing plaintiff’s ADA and FHA claims for any 22 amended complaint plaintiff may file. Because plaintiff has not stated a federal claim, the court 23 will not at this time exercise supplemental jurisdiction over plaintiff’s state law claims. See 28 24 U.S.C. § 1367(c)(3). If plaintiff states a federal claim, the court will screen the state law claims. 25 ADA 26 “To establish a violation of Title II of the ADA, a plaintiff must show that (1) [ ]he is a 27 qualified individual with a disability; (2) [ ]he was excluded from participation in or otherwise 28 discriminated against with regard to a public entity’s services, programs, or activities; and (3) 1 such exclusion or discrimination was by reason of [his] disability.” Lovell v. Chandler, 303 F.3d 2 1039, 1052 (9th Cir. 2002). To recover monetary damages under Title II of the ADA, a plaintiff 3 must also prove intentional discrimination on the part of the defendants. Duvall v. County of 4 Kitsap, 260 F.3d 1124, 1138 (9th Cir. 2001).

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Edward G. Eldridge v. Sherman Block
832 F.2d 1132 (Ninth Circuit, 1987)
Anna Harris v. Edna Itzhaki Rafael Itzhaki
183 F.3d 1043 (Ninth Circuit, 1999)
McDonald v. Coldwell Banker
543 F.3d 498 (Ninth Circuit, 2008)
Budnick v. Town of Carefree
518 F.3d 1109 (Ninth Circuit, 2008)
Doe I v. Wal-Mart Stores, Inc.
572 F.3d 677 (Ninth Circuit, 2009)
Cato v. United States
70 F.3d 1103 (Ninth Circuit, 1995)
Duvall v. County of Kitsap
260 F.3d 1124 (Ninth Circuit, 2001)

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(PS) Faruki v. Housing Authority for the County of Sacramento, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ps-faruki-v-housing-authority-for-the-county-of-sacramento-caed-2025.