Adams v. Community Housing Partnership

Background

Amy Adams leased a unit from Community Housing Partnership, doing business as HomeRise, through a Project-Based Voucher program. Under that program, HomeRise received monthly federal housing-assistance payments from the San Francisco Housing Authority to subsidize rental units for low-income tenants.

According to Adams’s complaint, the unit had multiple habitability problems, including apparent mold, torn carpet, a broken heater, and an exploding water heater. She alleged that she reported the problems to HomeRise, but they were not adequately repaired. She also alleged that HomeRise’s employees entered her home without warning, pressured her to return to the apartment before repairs were complete, and caused her housing assistance to be lost by falsely stating that she had abandoned the unit.

Adams further alleged that she repeatedly requested disability accommodations for herself and her daughter, but HomeRise did not provide them. She asserted eight claims: breach of the implied warranty of habitability, breach of the implied covenant of quiet enjoyment, negligence, intentional infliction of emotional distress, violations of the federal Fair Housing Act and California Fair Employment and Housing Act, violation of the Unruh Civil Rights Act, and violation of California Government Code section 11135.

Motion to Dismiss and Timeliness

HomeRise moved to dismiss all eight claims under Rule 12(b)(6), which asks whether a complaint alleges enough facts to state a legally plausible claim. HomeRise also argued that some claims were barred by statutes of limitations.

The court held that the complaint alleged events within the applicable limitations periods. For the habitability and quiet-enjoyment claims, the court identified a four-year limitations period and noted allegations involving the broken heater in 2020–2021 and the water-heater explosion in November 2021. The court also stated that continuing problems could potentially bring earlier related events within the limitations period, depending on facts developed in discovery.

The court concluded that the negligence and intentional-infliction-of-emotional-distress claims were timely because they were based at least partly on events occurring on or after November 22, 2021, within two years before Adams filed the complaint. It also concluded that the Unruh Act claim was timely under a three-year limitations period because Adams alleged that she first requested accommodations around June 30, 2021.

Disability-Accommodation Claims

For the Fair Housing Act and California Fair Employment and Housing Act claims, Adams alleged that she and her daughter had disabilities, that she requested reasonable accommodations necessary for their enjoyment of the unit, and that HomeRise denied the requests. The court emphasized that these claims are highly fact-specific and generally are not appropriate for dismissal based only on the pleadings.

HomeRise asked the court to consider documents concerning the termination of Adams’s housing assistance and the number of people living in the unit. The court declined to take judicial notice of those documents because they appeared incorrect or unauthenticated and were offered to establish disputed facts. The court concluded that HomeRise’s factual arguments had to wait for a later stage of the case.

The court also ruled that HomeRise could be subject to liability under California Government Code section 11135. That statute prohibits discrimination in programs operated or administered by the state or receiving state financial assistance. The court reasoned that the San Francisco Housing Authority provided the housing-assistance payments to HomeRise through the voucher program, and that the statute did not require the money to originate with California.

Disposition

Judge William H. Orrick denied HomeRise’s motion to dismiss as to all claims. The court did not determine whether Adams will win those claims; it determined only that the complaint plausibly alleged them and that dismissal based on the pleadings was not warranted. HomeRise was ordered to answer the complaint within fourteen days.