Laramore v. Quality Residence, LLC.

Background

Adrianne L. Laramore alleged that she rented a residence on Edgerton Street in Saint Paul, Minnesota, and that Quality Residences, LLC was responsible for the property. According to Laramore, a vehicle crashed into the property on January 17, 2021, damaging the residence and destroying medical items and equipment belonging to her 12-year-old daughter.

Local authorities determined that the property was not structurally fit for habitation. Laramore alleged that local housing authorities ordered Quality Residences to repair the property, but that repairs had not begun as of the date of the amended complaint. She alleged that she and her family were being forced to move and that it was difficult to find housing without rats and rodents. She sought compensation for emotional distress, pain, and suffering caused by being forced to live in hazardous conditions.

Laramore previously sought emergency and preliminary injunctive relief concerning the property and repairs. The court denied both requests. Quality Residences then moved for judgment on the pleadings under Rule 12(c) of the Federal Rules of Civil Procedure.

Legal standard

Judgment on the pleadings is appropriate when there are no material factual disputes and the moving party is entitled to judgment as a matter of law. The court applies the same legal standard used for a motion to dismiss for failure to state a claim. The complaint must allege enough facts to state a plausible claim for relief. The court accepts the nonmoving party’s factual allegations as true and draws reasonable inferences in that party’s favor, but legal conclusions and a bare list of a claim’s elements are not presumed true. The court also noted that pleadings by a self-represented litigant are read liberally and held to a less demanding standard than pleadings prepared by a lawyer.

Court’s analysis

Quality Residences argued that Laramore failed to state a claim because she identified no legal basis for relief. The amended complaint generally referred to 42 U.S.C. § 1983 and Section 8 of the United States Housing Act of 1937.

The court explained that Section 1983 does not itself create substantive rights; a Section 1983 claim must identify the specific federal right allegedly violated. Even when read liberally, Laramore’s amended complaint did not identify a specific federal statutory or constitutional right. The court also concluded that Section 8 of the Housing Act does not provide an implied private right to sue.

Because Laramore had not identified a legally recognized theory that could support relief, the court granted Quality Residences’ motion for judgment on the pleadings.

Disposition

Judge Wilhelmina M. Wright ordered that Quality Residences, LLC’s motion for judgment on the pleadings be GRANTED. The court also ordered that Laramore’s amended complaint be DISMISSED WITHOUT PREJUDICE, meaning the opinion did not bar refiling the complaint.