James B. Herrera v. Maddox Management, LLC

Summary

The United States District Court for the District of New Mexico dismissed James B. Herrera’s claims against Maddox Management, LLC under the Fair Housing Act and Rehabilitation Act. The court held that the Second Amended Complaint failed to plausibly allege discrimination, retaliation, disability, federal financial assistance, or a causal connection between protected activity and the defendant’s conduct. The court also noted that Herrera abandoned his procedural due process claim by omitting it from the Second Amended Complaint.

Holdings

1. The Second Amended Complaint failed to state a plausible Fair Housing Act claim because Plaintiff did not plead facts showing disability, discriminatory intent, a causal connection between protected status or activity and the alleged adverse actions, or that Defendant's rental verification contained the asserted false or misleading information.
2. The Second Amended Complaint failed to state a claim under § 504 of the Rehabilitation Act because Plaintiff did not plausibly allege that he was disabled, otherwise qualified, that Defendant was a covered program or activity receiving federal financial assistance, or that Defendant discriminated against him because of disability.
3. To the extent Plaintiff challenged the state-court judgment awarding damages, the federal court lacked jurisdiction under the Rooker-Feldman doctrine, and that portion of the claim had to be dismissed without prejudice.
4. The court was not required to sua sponte grant leave to amend a third time because Plaintiff had already been allowed to amend twice and failed to cure the identified pleading deficiencies.

Questions Presented

1. Whether the Second Amended Complaint plausibly stated a Fair Housing Act disability-discrimination, interference, or retaliation claim.
2. Whether the Second Amended Complaint plausibly stated a claim under § 504 of the Rehabilitation Act.
3. Whether any challenge to damages awarded in the state-court eviction judgment was barred by the Rooker-Feldman doctrine.
4. Whether the court was required to grant leave to amend a third time after Plaintiff failed to cure deficiencies identified in prior orders.

Disposition

dismissed