Bennett Robinson v. 12 Lofts Realty, Inc., and Paul Hanley

Summary

The Second Circuit addressed a Black purchaser's claim that a cooperative apartment corporation denied his application because of race in violation of the Fair Housing Act and 42 U.S.C. §§ 1981 and 1982. The court held that Robinson established a prima facie case and that the corporation had not adequately rebutted the inference of discrimination because it failed to provide evidence from the shareholders who voted against the purchase. The court reversed and remanded for further proceedings, stating that Robinson would be entitled to injunctive relief if those shareholders did not testify.

Holdings

1. An individual plaintiff establishes a prima facie case of discriminatory denial of housing under 42 U.S.C. § 3604(a) by showing that he is Black, applied for and was qualified to purchase or rent the housing, was rejected, and that the housing opportunity remained available. Proof of discriminatory motivation is not required at the prima facie stage.
2. The corporation did not rebut Robinson's prima facie case by relying on hypothetical rumors and subjective reactions without identifying or presenting testimony from the four shareholders whose negative votes defeated the purchase.
3. A denial of housing violates 42 U.S.C. § 3604(a) if race is one motivating factor; race need not be the sole motivating factor.
4. The district court had to conduct further proceedings to determine whether the four negative voters genuinely held the stated reasons, whether those reasons caused their votes, and whether racial motivation played any role; if the negative voters did not testify, Robinson would be entitled to injunctive relief.

Questions Presented

1. Whether Robinson established a prima facie case of racial discrimination under section 3604(a) of the Fair Housing Act based on discriminatory effect without initially proving discriminatory intent.
2. Whether the corporation rebutted Robinson's prima facie case by presenting evidence of legitimate, nonracial reasons for the rejection when the actual four negative voters were not identified or called to testify.
3. Whether race must be the sole motivating factor for a denial of housing, or whether a denial violates section 3604(a) when race is one motivating factor.
4. What further proceedings were required to determine whether the corporation's stated reasons were genuine and whether racial motivation played any role in the rejection.

Disposition

reversed_and_remanded