Recent New York Court Decisions on ADA and FHA Claims

In the United States, individuals with disabilities are protected by the Americans with Disabilities Act (ADA) and the Fair Housing Act (FHA), which aim to prevent discrimination based on disability. In recent court decisions, Avila v. Acacia Network, Inc. and Hanyzkiewicz v. Allegiance Retail Servs., LLC, plaintiffs brought forward ADA and FHA claims against defendants for alleged violations.

Avila v. Acacia Network, Inc. involved a plaintiff who brought forward an FHA and ADA claim against a landlord for failing to comply with a doctor's recommendation for transfer to a one-bedroom apartment. The court found that the plaintiff failed to state a claim but granted leave to amend. To state a claim of intentional discrimination under the FHA, the plaintiff must allege that they were a member of a protected class, suffered relevant adverse treatment, and can sustain a minimal burden of showing facts suggesting an inference of discriminatory motivation. Under the ADA Title III, it is discriminatory to afford an individual or class of individuals, on the basis of a disability, the opportunity to participate in or benefit from a good, service, facility, privilege, advantage, or accommodation that is not equal to that afforded to other individuals. The court found that the plaintiff failed to state a claim under both the FHA and ADA Title III.

Hanyzkiewicz v. Allegiance Retail Servs., LLC involved a plaintiff who alleged ADA Title III and NYCHRL violations based on an inaccessible website. The defendant was subject to a consent decree from a prior case and had remediated its website, but the plaintiff claimed that accessibility issues remained. The court found that the plaintiff's suit must be enjoined because it could upset the consent decree, which includes a proposed class that is absent from the consent decree and seeks materially different remedies. The court also found that the defendant's voluntary cessation of discriminatory conduct did not moot the case.

In conclusion, these recent court decisions highlight the importance of understanding the rules and requirements of the ADA and FHA when bringing forward claims. Plaintiffs must allege the necessary facts to state a claim under these acts, and the courts must ensure that consent decrees are respected and enforced. For individuals with disabilities, these decisions offer insight into their legal protections and avenues for seeking justice when their rights have been violated.

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