Lisa R. Wrighten v. Old Linco LLC and Charlie R. Oliver

Summary

The court denied the parties’ cross-motions for summary judgment in a Fair Housing Act action concerning alleged disability discrimination and retaliation related to a tenant’s emotional support animal. The court also denied defendants’ counterclaims because they were not compulsory and lacked supporting summary-judgment evidence. The court found a genuine dispute of material fact regarding whether the requested accommodation was necessary to provide the plaintiff an equal opportunity to use and enjoy the dwelling.

Holdings

1. Defendants' counterclaims for unpaid rent and fire damage did not arise out of the same transaction or occurrence as Plaintiff's Fair Housing Act civil-rights claims and therefore were not compulsory counterclaims.
2. Defendants were not entitled to summary judgment on their counterclaims because they provided no summary-judgment evidence supporting those claims.
3. Plaintiff was not entitled to summary judgment because a genuine dispute of material fact existed regarding whether the requested animal accommodation was necessary to afford her an equal opportunity to use and enjoy the dwelling.

Questions Presented

1. Whether Defendants' counterclaims for unpaid rent and property damage were compulsory counterclaims arising from the same transaction or occurrence as Plaintiff's Fair Housing Act claims.
2. Whether Defendants were entitled to summary judgment on their counterclaims when they submitted no summary-judgment evidence supporting them.
3. Whether Plaintiff was entitled to summary judgment on her Fair Housing Act reasonable-accommodation claim when the evidence left a genuine dispute regarding whether the requested animal was necessary to afford her an equal opportunity to use and enjoy the dwelling.

Disposition

other