Marcos Isaac Rojas v. Shelter Corporation and Kyle Didier

Summary

The United States District Court for the District of Minnesota granted in part and denied in part Defendants’ motion to dismiss claims arising from alleged race-based harassment and discrimination at an apartment complex. The court dismissed the plaintiff’s Fair Housing Act disparate-impact and retaliation claims without prejudice, finding the allegations insufficient and noting the statute of limitations. The court declined supplemental jurisdiction over the remaining state-law claims and remanded them to Minnesota state court.

Holdings

1. Rojas failed to state a plausible FHA disparate-impact claim because he did not allege facts showing that Defendants knew of the alleged tenant misconduct, failed to act, and thereby created or implemented a policy or practice that adversely impacted minorities.
2. Rojas failed to state a plausible FHA retaliation claim because the allegation that Didier installed a camera directed at Rojas’s parking space was too vague and conclusory to support relief.
3. The court declined to exercise supplemental jurisdiction over the remaining state-law claims and remanded them to the Minnesota state court because all claims within the court's original jurisdiction had been dismissed.

Questions Presented

1. Whether Rojas plausibly alleged a disparate-impact claim under the Fair Housing Act.
2. Whether Rojas plausibly alleged that Kyle Didier retaliated against him in violation of the Fair Housing Act.
3. Whether the court should exercise supplemental jurisdiction over the remaining Minnesota state-law claims after dismissing all federal claims.

Disposition

reversed_and_remanded