Harris v. Community Housing Mangament Corp.

Background

Ronald W. Harris, Sr., proceeding without a lawyer, sued Community Housing Management Corp. (CHMC), Huguenot Housing Associates, LLC (HHA), and “Owner of the Huguenot House.” The opinion states that HHA owned the building and CHMC managed it, and treated “Owner of the Huguenot House” as indistinguishable from HHA for purposes of the motion. Harris’s amended complaint asserted disability-discrimination claims under the Fair Housing Act and the Americans with Disabilities Act based on the alleged failure to provide an accessible parking space at Huguenot House.

The court described Huguenot House as a federally subsidized housing facility. Harris had previously pursued related housing-discrimination complaints before government agencies. During those proceedings, CHMC created accessible parking spaces. The record also showed that, through a settlement process, Harris accepted and cashed a replacement check from HHA for $6,000. The defendants later created additional accessible spaces and offered Harris one with aisle access in the front parking lot. Harris eventually refused that offer.

Motion and Mootness

After discovery, the defendants moved for summary judgment under Rule 56 of the Federal Rules of Civil Procedure. Summary judgment is a decision without a trial when the evidence shows no genuine dispute over a fact important to the case and the moving party is entitled to judgment as a matter of law. The court reviewed Harris’s opposition papers and evidence despite his not filing a separate statement required by a local rule.

The court focused on whether the case had become moot. A case is moot when a live dispute no longer exists and the requested relief can no longer be given or is no longer needed. The court noted that Harris had informed it that his driver’s license would not be renewed because of his medical condition. His ophthalmologist stated that Harris no longer met the legal vision requirements for operating a motor vehicle. Harris also provided a copy of his expired license and testified that he had not driven since at least June or July 2015.

Based on this evidence, the court concluded that Harris no longer had a personal stake in obtaining an accessible parking space. Because he could no longer drive, the court found that he no longer needed the requested accommodation and was no longer being deprived of it. The opinion therefore resolved the case on mootness rather than deciding whether the defendants had violated the Fair Housing Act or the Americans with Disabilities Act.

Disposition

Judge Andrew E. Krause granted the defendants’ motion for summary judgment, dismissed the case as moot, directed the Clerk to enter judgment for the defendants, and terminated the motions at ECF Nos. 60 and 72. The opinion does not state that the dismissal was with or without prejudice.