WARNER v. ANDERSON HOUSING AUTHORITY

CourtDistrict Court, S.D. Indiana
DecidedSeptember 30, 2025
Docket1:23-cv-00096
StatusUnknown

This text of WARNER v. ANDERSON HOUSING AUTHORITY (WARNER v. ANDERSON HOUSING AUTHORITY) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
WARNER v. ANDERSON HOUSING AUTHORITY, (S.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

BRADLEY D. WARNER, ) ) Plaintiff, ) ) v. ) No. 1:23-cv-00096-JPH-CSW ) LORRAINE RICHARDSON, ) MARY DAVIS, ) ) Defendants. )

ORDER GRANTING DEFENDANTS' MOTION FOR SUMMARY JUDGMENT Plaintiff Bradley D. Warner alleges that Anderson Housing Authority (AHA) employees violated his due process rights by wrongfully evicting him and denying his request for a hearing regarding his lease termination. Defendants, Mary Davis and Lorraine Richardson, have moved for summary judgment, arguing that Mr. Warner was not entitled to a hearing and that they are entitled to qualified immunity. Dkt. [60]. For the reasons below, that motion is GRANTED. I. Facts and Background Because Defendants have moved for summary judgment under Rule 56(a), the Court views and recites the evidence "in the light most favorable to the non-moving party and draw[s] all reasonable inferences in that party's favor." Zerante v. DeLuca, 555 F.3d 582, 584 (7th Cir. 2009) (citation omitted). In 2020, Mr. Warner entered a lease agreement with the AHA, a public- housing agency that administers Section 8 housing vouchers. Dkt. 62-1 at 14– 15. The agreement's "Termination of Lease" provision allowed termination for, among other things, "[c]riminal activity by the Tenant . . . including criminal activity that threatens the health, safety or right to peaceful enjoyment of the Authority's public housing premises by other residents." Id. at 10–11.

On June 10, 2021, Mr. Warner came to Ms. Davis, the apartment manager, and told her that children were in distress in another unit. Dkt. 62-2 at 1. Ms. Davis and Mr. Warner visited that unit, and Mr. Warner forced his way in when the tenants answered the door. Id. at 1–2. He began arguing with the tenant and yelled at Ms. Davis when she attempted to intervene.1 Id. Police were dispatched to the apartment complex in response to this confrontation. Id. at 1. Later that day, Mr. Warner was arrested and charged with Residential Entry. Id. at 2. He pled guilty in November 2022. Dkt. 62-3.

On June 10, 2021, Ms. Davis issued a Notice of Violation ("Notice") to Mr. Warner, indicating that the AHA intended to terminate his lease. Dkt. 62-4. The Notice cited a violation of the criminal activity lease provision and stated that Mr. Warner had seventy-two hours after service of the Notice to vacate the property. Id. Mr. Warner vacated the unit as directed and requested a hearing on the basis of "wrongful eviction." Dkt. 62-5. On June 30, 2021, the Housing and Compliance Manager, Lorraine

Richardson, denied this request, reasoning that a hearing was "not warranted"

1 Mr. Warner contests the allegations about his forced entry and the nature of his interaction with the tenant and Ms. Davis, but he has designated no evidence placing these facts in dispute. See Dkt. 63 at 7–9; Redd v. Nolan, 663 F.3d 287, 292 (7th Cir. 2011). because "there was no eviction." Id. Rather, Mr. Warner's lease was terminated due to "program violations" and he "complied by vacating the unit." Id. Mr. Warner filed this case in January 2023, dkt. 1; dkt. 9 (operative

complaint), and is proceeding on procedural due process claims against Ms. Davis and Ms. Richardson in their individual capacities, dkt. 41 at 15 (order dismissing other claims and defendants). On February 26, 2025, Defendants filed a motion for summary judgment. Dkt. 60. II. Summary Judgment Standard Summary judgment shall be granted "if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed. R. Civ. P. 56(a). The moving party must inform the Court "of the basis for its motion" and specify evidence demonstrating "the absence of a genuine issue of material fact." Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). Once the moving party meets this

burden, the nonmoving party must "go beyond the pleadings" and identify "specific facts showing that there is a genuine issue for trial." Id. at 324. In ruling on a motion for summary judgment, the Court views the evidence "in the light most favorable to the nonmoving party and draw[s] all reasonable inferences in that party's favor." Zerante, 555 F.3d at 584 (citation omitted). III. Analysis Defendants argue they are entitled to summary judgment because they did not deprive Mr. Warner of any required hearing and, regardless, are entitled to qualified immunity. Dkt. 61 at 5–7. Mr. Warner responds that his procedural due process rights were violated when he was "illegal[ly] evict[ed]" and denied a hearing, and that qualified immunity should not apply because Defendants acted with "malicious intent." Dkt. 63 at 28–29.

"[Q]ualified immunity shields officials from civil liability so long as their conduct 'does not violate clearly established statutory or constitutional rights of which a reasonable person would have known.'"2 Mullenix v. Luna, 577 U.S. 7, 11 (2015) (quoting Pearson v. Callahan, 555 U.S. 223, 232 (2009)); This "clearly established" standard ensures "that officials can 'reasonably . . . anticipate when their conduct may give rise to liability for damages.'" Reichle v. Howards, 566 U.S. 658, 664 (2012) (quoting Anderson v. Creighton, 483 U.S. 635, 646 (1987)). Qualified immunity thus "balances two important interests—

the need to hold public officials accountable when they exercise power irresponsibly and the need to shield officers from harassment, distraction, and liability when they perform their duties reasonably." Pearson, 555 U.S. at 231.

2 Defendants cite a different qualified immunity standard set out in Young v. Peoria Housing Auth., 479 F. Supp. 1093, 1096 (C.D. Ill. 1979), but Young applied a prior qualified-immunity test under which qualified immunity was inappropriate if a defendant acted with a "malicious intention" of violating constitutional rights. Id. That subjective test no longer applies, see Harlow v. Fitzgerald, 457 U.S. 800, 817–18 (1982), so the parties' dispute about whether Defendants acted with malicious intention does not affect the analysis. Dkt. 61 at 7–8; dkt. 63 at 28–29. The "difficult part" of the qualified-immunity test is "identifying the level of generality at which the constitutional right must be clearly established." Volkman v. Ryker, 736 F.3d 1084, 1090 (7th Cir. 2013). A "high level of generality" is not appropriate; instead, the question is "whether the law was

clear in relation to the specific facts confronting the public official when he acted." Id. The analysis must proceed defendant-by-defendant, Mabes v. Thompson, 136 F.4th 697, 705 (7th Cir. 2025), and a court may address the "clearly established" prong first. Leiser v. Kloth, 933 F.3d 696, 701 (7th Cir. 2019). The plaintiff bears the burden of overcoming qualified immunity when the defense is invoked at summary judgment. Mabes, 136 F.4th at 705.

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

Related

Goldberg v. Kelly
397 U.S. 254 (Supreme Court, 1970)
Harlow v. Fitzgerald
457 U.S. 800 (Supreme Court, 1982)
Anderson v. Creighton
483 U.S. 635 (Supreme Court, 1987)
Brosseau v. Haugen
543 U.S. 194 (Supreme Court, 2004)
Pearson v. Callahan
555 U.S. 223 (Supreme Court, 2009)
Redd v. Nolan
663 F.3d 287 (Seventh Circuit, 2011)
Sierra Resources, Incorporated v. Alexis M. Herman
213 F.3d 989 (Seventh Circuit, 2000)
Reichle v. Howards
132 S. Ct. 2088 (Supreme Court, 2012)
Zerante v. DeLuca
555 F.3d 582 (Seventh Circuit, 2009)
Young v. Peoria Housing Authority
479 F. Supp. 1093 (C.D. Illinois, 1979)
Mullenix v. Luna
577 U.S. 7 (Supreme Court, 2015)
Jeffrey Leiser v. Karen Kloth
933 F.3d 696 (Seventh Circuit, 2019)
Volkman v. Ryker
736 F.3d 1084 (Seventh Circuit, 2013)
Isaiah Taylor v. Justin Schwarzhuber
132 F.4th 480 (Seventh Circuit, 2025)
Erika Mabes v. Shannon Thompson
136 F.4th 697 (Seventh Circuit, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
WARNER v. ANDERSON HOUSING AUTHORITY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/warner-v-anderson-housing-authority-insd-2025.