Summary
The Connecticut Supreme Court affirmed a judgment against landlords who refused to rent housing after rejecting a security-deposit guarantee provided through a state assistance program. The court held that the guarantee qualified as a lawful source of income under Connecticut housing-discrimination statutes and that its alleged invalidity was irrelevant because it did not motivate the landlords’ decision. The court also upheld the trial court’s jurisdiction and damages ruling, while declining to reach several inadequately briefed constitutional and discovery claims.
Topics
Practice areas
Questions Presented
- Whether the trial court lost personal jurisdiction because it rendered judgment more than 120 days after the completion of trial under General Statutes § 51-183b.
- Whether a state security-deposit guarantee constitutes a lawful source of income under General Statutes §§ 46a-63 (3) and 46a-64c.
- Whether the alleged invalidity of the guarantee was relevant to the housing-discrimination claim when the defendants admitted that they rejected it because they required a cash deposit.
- Whether the trial court abused its discretion by awarding compensatory damages to Arnold and her children.
- Whether the defendants' discovery claim was adequately briefed for appellate review.
- Whether the defendants' equal-protection and vagueness challenges were adequately briefed for appellate review.
Holdings
- When a trial court properly reopens a case during the statutory 120-day period by ordering an additional proceeding, the completion of that proceeding becomes the new completion date for calculating the time to render judgment. The trial court therefore retained personal jurisdiction to enter judgment.
- A state security-deposit guarantee is a lawful source of income within the meaning of General Statutes §§ 46a-63 (3) and 46a-64c, and refusing to rent because the prospective tenant offered the guarantee instead of cash constitutes prohibited housing discrimination.
- The alleged invalidity of a security-deposit guarantee is irrelevant to a direct-evidence discrimination claim when the defendants did not rely on that alleged defect at the time they rejected the prospective tenants.
- The compensatory-damages awards to Arnold and her children did not constitute an abuse of discretion or shock the judicial conscience. Under the circumstances, the trial court reasonably could infer that the children suffered emotional harm from events inherently likely to cause mental and emotional distress.
Key quotations
“Accordingly, to constitute income, something does not need to be money; rather, it can be something else of value.” (302 Conn. 263, 284; 25 A.3d 632, 641)
“The critical inquiry is whether the discriminatory motive was a factor in the decision at the moment it was made.” (302 Conn. 263, 288; 25 A.3d 632, 642)
“The damages award in this case falls within the broad contours of the trial judge's discretion and does not shock the judicial conscience of this court.” (302 Conn. 263, 297; 25 A.3d 632, 648)
Factual background
Arnold sought to rent an apartment owned by the defendants and was told that she needed a cash security deposit equal to twice the monthly rent. She offered a state security-deposit guarantee in lieu of cash, and the defendants initially agreed, but later refused to allow Arnold and her children to take possession because the deposit had not been paid in cash. The family then lived in temporary and later alternative housing where they experienced cramped and unsafe conditions, including exposure to drug activity and gun violence.
Procedural history
Arnold and her children filed a housing-discrimination complaint after the defendants refused to rent an apartment when Arnold offered a state security-deposit guarantee instead of cash. The commission brought the action on the relators' behalf. After trial, the Superior Court found a violation of General Statutes § 46a-64c and awarded compensatory and punitive damages, a civil penalty, and attorney's fees. The Supreme Court affirmed.