Weatherspoon v. Arfaei

Background Wayne Weatherspoon alleged that he has epilepsy and uses a trained assistance dog to protect him during seizures. He also alleged that he rents a residential property from Reza Arfaei. According to the complaint, after Weatherspoon told Arfaei that he had an assistance animal, Arfaei said he would raise the rent and later gave Weatherspoon a termination notice that cited a no-pet policy as a reason for ending the tenancy.

Weatherspoon asserted claims under the Fair Housing Act, 42 U.S.C. §§ 3601–19; California’s Fair Employment and Housing Act, Cal. Gov. Code §§ 12900–96; and the Unruh Civil Rights Act, Cal. Civ. Code § 51.

Motion to dismiss Arfaei moved to dismiss the complaint. In deciding a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), the court assumes the complaint’s factual allegations are true and considers whether they state a plausible claim for relief. The court held that Weatherspoon’s allegations were more than bare assertions or a formulaic statement of legal elements and were sufficient to support his three claims.

Arfaei relied on declarations and other evidence outside the pleadings. The court declined to consider that material when evaluating the motion because a court generally may not consider material beyond the pleadings on a Rule 12(b)(6) motion.

Disposition The court concluded that Weatherspoon had stated plausible claims for relief and denied Arfaei’s motion to dismiss. The order did not decide the ultimate merits of the claims.