Williams v. Settle Homes

Background

Michael O. Williams proceeded without a lawyer and sought permission to proceed without prepaying filing fees. He sued Settle Homes, Eugene, and Marcos under the court’s federal-question jurisdiction. Williams alleged that he was refused a room at 154 Madison Street in August 2023 because of his income and “choice of occupation.” He stated that he was a student and trader and sought $15,000 in damages.

The complaint attached text messages in which Williams described himself as a Master of Business Administration student, a full-time stock-market trader, and an entrepreneur. Eugene responded that Williams did not qualify to rent an apartment without a current documented steady source of income and suggested applying with a guarantor.

Federal Fair Housing Act claims

The court construed the complaint as asserting claims under the Fair Housing Act, a federal law that prohibits certain forms of housing discrimination. The court explained that the Act protects people from discrimination in renting because of characteristics including race, color, religion, sex, familial status, national origin, or disability. It also prohibits retaliation for exercising rights under the Act.

The court held that Williams did not allege discrimination based on any protected characteristic. Income, source of income, and choice of occupation are not protected classes under the Fair Housing Act. The court therefore dismissed the federal claims for failure to state a claim for relief under 28 U.S.C. § 1915(e)(2)(B)(ii), the provision requiring dismissal of certain claims in complaints filed without prepaying fees.

State-law claims and jurisdiction

The court noted that lawful source of income is a protected class under the New York State Human Rights Law. But Williams did not allege facts establishing diversity jurisdiction, which generally requires opposing parties to be citizens of different states and a claimed amount exceeding $75,000. The opinion states that Williams and Settle Homes reside in New York and that Williams sought $15,000.

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction—the court’s discretionary authority to hear related state-law claims—over any state-law claims Williams might be asserting.

Leave to amend and disposition

The court denied leave to amend because it concluded that the defects were clear from the face of the complaint and could not be cured by amendment. The complaint was dismissed for failure to state a claim. The court certified that any appeal would not be taken in good faith and denied Williams permission to appeal without prepaying fees. It directed the Clerk of Court to enter judgment.