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

District Court, E.D. California·Decided April 28, 2025·No. 2:25-cv-00507·Unknown

Opinion

MEKAL FARUKI, No. 2:25-cv-0507-DJC-CKD (PS) Plaintiff, v. ORDER HOUSING AUTHORITY FOR THE COUNTY OF SACRAMENTO, et al., Defendants.

Plaintiff Mekal Faruki proceeds without counsel1 and alleges housing discrimination by public housing authorities. Plaintiff’s request to proceed in forma pauperis makes the showing required by 28 U.S.C. § 1915. (ECF No. 2.) Plaintiff’s request to proceed in forma pauperis is granted. However, the complaint fails to state a claim and must be dismissed. Plaintiff is granted leave to file an amended complaint within 30 days of the date of this order. I. Screening Requirement Pursuant to 28 U.S.C. § 1915(e), the court must screen every in forma pauperis proceeding, and must order dismissal of the case if it is “frivolous or malicious,” “fails to state a claim on which relief may be granted,” or “seeks monetary relief against a defendant who is 1 Because plaintiff proceeds without counsel, this action is referred to the undersigned by Local Rule 302(c)(21) pursuant to 28 U.S.C. § 636. immune from such relief.” 28 U.S.C. § 1915(e)(2)(B); Lopez v. Smith, 203 F.3d 1122, 1126-27 (2000). In performing this screening, the court liberally construes a pro se plaintiff’s pleadings. See Eldridge v. Block, 832 F.2d 1132, 1137 (9th Cir. 1987). A complaint must contain “a short and plain statement of the claim showing that the pleader is entitled to relief....” Fed. R. Civ. P. 8(a)(2). Detailed factual allegations are not required, but “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice[.]” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)). While factual allegations are accepted as true, legal conclusions are not. Iqbal, 556 U.S. at 678. Courts “are not required to indulge unwarranted inferences[.]” Doe I v. Wal-Mart Stores, Inc., 572 F.3d 677, 681 (9th Cir. 2009) (internal quotation marks and citation omitted). Pro se litigants are entitled to have their pleadings liberally construed and to have any doubt resolved in their favor, Eldridge, 832 F.2d at 1137, but a plaintiff’s claims must be facially plausible to survive screening. Facial plausibility for a claim requires sufficient factual detail to allow the court to reasonably infer that a named defendant is liable for the misconduct alleged. Iqbal, 556 U.S. at 678. II. Plaintiff’s Allegations Plaintiff is elderly and “a qualified individual with a disability” who was [u]ndergoing cancer chemotherapy and suffering its severe side effects, including extreme fatigue, cognitive impairment, neuropathy and physical weakness.” (ECF No. 1 at 2, 7.) Defendants are public housing authorities responsible for administering Section 8 Housing Choice Vouchers. (Id. at 2.) Plaintiff applied for and met all eligibility requirements for a Section 8 Housing Choice Voucher, but “[o]ver the course of 90 incidents, Defendants denied, delayed, or failed to process Plaintiff’s Section 8 voucher application and renewal requests, solely based on Plaintiff’s disability and elder status.” (Id.) Defendants engaged in a pattern and practice of systemic discrimination, including refusing to grant a reasonable accommodation for expedited processing of plaintiff’s voucher, deliberately delaying the application process while approving non-disabled applicants, providing false or misleading information about voucher availability and plaintiff’s eligibility, and failing to make necessary policy modifications in violation of federal and state law. (ECF No. 1 at 2.) Plaintiff actively pursued his claims but “defendants continued to deny assistance[.]” (Id.) Defendants’ misconduct included “90 instances of denying Section 8 vouchers[.]” (Id. at 3.) Plaintiff brings five causes of action as follows: (1) Violations of the ADA (42 U.S.C. § 12101 et seq.); (2) Violations of the FHA (42 U.S.C. § 3601 et seq.; (3) Violations of the Unruh Civil Rights Act (Cal. Civ. Code § 51); (4) Violation of California Disabled Persons Act (“CDPA”) (Cal. Civ. Code § 54); and (5) Fraud (Cal. Civ. Code § 1708). (ECF No. 1 at 3-4.) Plaintiff seeks damages and injunctive relief. (Id. at 4.) III. Discussion The complaint contains many generalized statements and conclusions but is short on factual allegations describing specifically how defendants discriminated against plaintiff, denied plaintiff assistance, or denied a reasonable accommodation. The complaint mostly contains conclusions that defendants subjected plaintiff to housing discrimination. However, general allegations that defendants deliberately delayed or denied plaintiff assistance, provided false or misleading information, and engaged in “90 instances” of misconduct are too vague to state a claim for relief. Conclusory allegations like these do not give fair notice of the claims. See Iqbal, 556 U.S. at 678. Having performed the screening required by 28 U.S.C. § 1915, the court finds plaintiff fails to state a claim under the ADA or the FHA. Plaintiff will have an opportunity to amend. Below, the court sets forth legal standards governing plaintiff’s ADA and FHA claims for any amended complaint plaintiff may file. Because plaintiff has not stated a federal claim, the court will not at this time exercise supplemental jurisdiction over plaintiff’s state law claims. See 28 U.S.C. § 1367(c)(3). If plaintiff states a federal claim, the court will screen the state law claims. ADA “To establish a violation of Title II of the ADA, a plaintiff must show that (1) [ ]he is a qualified individual with a disability; (2) [ ]he was excluded from participation in or otherwise discriminated against with regard to a public entity’s services, programs, or activities; and (3) such exclusion or discrimination was by reason of [his] disability.” Lovell v. Chandler, 303 F.3d 1039, 1052 (9th Cir. 2002). To recover monetary damages under Title II of the ADA, a plaintiff must also prove intentional discrimination on the part of the defendants. Duvall v. County of Kitsap, 260 F.3d 1124, 1138 (9th Cir. 2001). The standard for intentional discrimination is deliberate indifference, which requires the plaintiff to show that the defendant knew “harm to a federally protected right [wa]s substantially likely” and failed to act upon that likelihood. Id. at 1139. Plaintiff alleges he suffered discrimination because

Free access — add to your briefcase to read the full text and ask questions with AI

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

(PS) Faruki v. Housing Authority for the County of Sacramento ((PS) Faruki v. Housing Authority for the County of Sacramento) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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)