Rutland Court Owners, Inc. v. Taylor

Summary

The District of Columbia Court of Appeals affirmed a judgment denying possession of a cooperative apartment after the cooperative revoked the shareholder-tenant's shares. The court held that the Fair Housing Act required consideration of a reasonable accommodation for the tenant's mental disabilities, including additional time and professional assistance to clean and exterminate his unit. Because the accommodation was ultimately implemented with court assistance and the cooperative failed to show an unmanageable health or safety threat, the judgment was affirmed.

Holdings

1. Taylor established the elements of a reasonable-accommodation defense: disability, the cooperative's knowledge of the disability, necessity of the accommodation, reasonableness, and refusal by the cooperative.
2. A request for a reasonable accommodation need not be made in any particular form and need not contain a detailed proposal for the accommodation.
3. The direct-threat exception does not eliminate the duty to provide a reasonable accommodation until the court evaluates whether an accommodation could sufficiently protect the health, safety, and property of others.
4. The judgment denying possession was proper because the cooperative's failure to provide the reasonable accommodation constituted a discriminatory act, and the accommodation was ultimately accomplished.

Questions Presented

1. Whether Taylor established a Fair Housing Act defense based on the denial of a reasonable accommodation for a disability.
2. Whether a request for reasonable accommodation must be made in a particular form or include a detailed proposal.
3. Whether the Fair Housing Act's direct-threat exception defeated Taylor's reasonable-accommodation defense.
4. Whether the trial court erred in denying possession after the cooperative revoked Taylor's shares.

Disposition

affirmed