United States v. City of Chattanooga, Tennessee

District Court, E.D. Tennessee·Decided December 8, 2023·No. 1:23-cv-00258·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE

UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) No.: 1:23-CV-258-TAV-CHS ) CITY OF CHATTANOOGA, ) TENNESSEE, ) ) Defendant. )

CONSENT DECREE

The United States of America alleges as follows:

I. BACKGROUND

1. The United States brings this action for declaratory and injunctive relief, monetary damages, and a civil penalty against the City of Chattanooga, Tennessee (the “City” or the “Defendant”), under the Fair Housing Act, Title VIII of the Civil Rights Act of 1968, as amended (“FHA”), 42 U.S.C. §§ 3601–3631, and Title II of the Americans with Disabilities Act of 1990, as amended (“ADA”), 42 U.S.C. §§ 12131–12134, and Title II’s implementing regulation, 28 C.F.R. Part 35. The complaint alleges that the City discriminated on the basis of disability1 by refusing to

1 Although the FHA uses the term “handicap” instead of “disability,” the words have the same legal meaning. See Bragdon v. Abbott, 524 U.S. 624, 631 (1998). These equivalent terms refer to the definitions included in the Fair Housing Act, see 42 U.S.C. § 3602(h); 24 C.F.R. § 100.201; and in the Americans with Disabilities Act, see 42 U.S.C. § 12102(1); 28 C.F.R. § 35.104. allow four people with mental disabilities to reside together in a single-family home in the City under the same terms and conditions as residents without disabilities. The United States alleges that through its actions and implementation of its zoning ordinance, the

City is alleged to have engaged in a discriminatory housing practice and denied rights granted by the FHA and the ADA, and such denial raises an issue of general public importance. 2. As described in the United States’ Complaint, this case concerns the efforts of Quality Lifestyle Service, Inc. (“Quality Lifestyle”), a registered Tennessee 501(c)(3)

non-profit corporation, beginning in June 2020 to provide housing (through a “Housing Initiative” or “Initiative”) to four unrelated persons with mental illness who would have lived together at 1104 South Greenwood Avenue, a four-bedroom home in an R-1 zoning district in the City (“subject property”). Tennessee law, Tenn. Code Ann. §§ 13 24 101–104, removes zoning obstacles preventing persons with mental and physical

disabilities from obtaining equal access to housing in Tennessee. Tenn. Code Ann. § 13-24-103 states that this law “takes precedence over any provision in any zoning law or ordinance in Tennessee to the contrary.” The City Zoning Ordinance defines single-family residences to include any home in which eight (8) or fewer unrelated persons with disabilities reside and may include three (3) additional persons acting as support staff or

guardians, who need not be related to each other in a single-family zoned property pursuant to Tenn. Code Ann. § 13-24-102.

2 3. Ursula Edwards is the Chief Executive Officer and owner of Quality Lifestyle, which provides property management services to support housing for persons with disabilities. During relevant times, a private person that was not a nonprofit entity

owned the subject property and Quality Lifestyle Services was operating under a lease agreement for the subject property to provide property management services in conjunction with the Mental Health Cooperative of Chattanooga and Blue Cross Blue Shield of Tennessee. 4. The Initiative was a collaboration among a number of community

stakeholders, including the Hamilton County FUSE program, who sought to provide housing to persons with disabilities in the City. 5. As described in the United States’ Complaint, it is alleged that the City took steps, including imposing the requirements that Quality Lifestyle obtain a special permit, that thwarted Quality Lifestyle’s efforts to provide housing for persons with disabilities

through the Initiative. As a result, Ms. Edwards and the Housing Initiative participants were unable to provide housing to persons with disabilities at the subject property. 6. Regarding the FHA, the United States alleges that the City’s actions described above constitute violations of the FHA §§ 3601-3619; a denial of rights to a group of persons that raises an issue of general public importance, in violation of the Fair

Housing Act, 42 U.S.C. §§ 3614(a); and a discriminatory housing practice involving the legality of a state or local zoning or other land use law or ordinance, in violation of 42 U.S.C. § 3614(b). 3 7. Regarding the ADA, the United States alleges that the City’s actions described above constitute discrimination in violation of Title II of the ADA, 42 U.S.C. § 12132, and its implementing regulation, 28 C.F.R. Part 35; and interfere with an

individual in the exercise or enjoyment of, or on account of his or her having exercised or enjoyed, or on account of his or her having aided or encouraged any other individual in the exercise or enjoyment of, any right granted or protected by the ADA, in violation of Title V of the ADA, 42 U.S.C. § 12203(b). 8. The City has denied that it discriminated against Quality Lifestyle in that the

City initially determined that the proposal did not meet the safe harbor of Tenn. Code Ann. § 13-21-101. As a result, the special permit for operation of a group home was denied during a hearing on November 4, 2020. Although the City refused to allow Quality Lifestyle to open and operate the home at the subject property, it has allowed residences for persons with disabilities managed by Quality Lifestyle to operate in other locations in

the City. 9. This Consent Decree (the “Decree”) is intended to effectuate a comprehensive settlement of the United States’ claims. To avoid litigation, the United States and the City (collectively, the “Parties”) have jointly and voluntarily agreed to resolve the United States’ claims, as indicated by the signatures below. By entering into

this Decree, the City does not admit that it violated the FHA or the ADA. This Decree is not an adverse finding, ruling, proceeding, or judgment against the City. Therefore, it is hereby ORDERED, ADJUDGED, and DECREED as follows: 4 II. JURISDICTION AND VENUE 10.

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United States v. City of Chattanooga, Tennessee, (E.D. Tenn. 2023).

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Related

Bragdon v. Abbott
524 U.S. 624 (Supreme Court, 1998)