HomeMy WebLinkAboutMinutes Human Relations Commission - 08/04/2011 •
Corpus Christi Human Relations Commission
Summary of Minutes for August 4, 2011C��V ®
1. CALL TO ORDER DEC 01 2011
Chairperson Ramiro Gamboa called the meeting to order at 5:00 p.m.
CIN SECRETARY'S OF ,
A. ROLL CALL
Present Commissioners:
Ramiro Gamboa Denise Villagran Abel Alonzo
Robert Adler Carlos Aguinaga Edna Arredondo
Kathleen Cooper Robert Franklin Margie Myers
Pastor Derrick Reaves Lucy Reta Elias Valverde
Brianna Mendiola (Youth) Jacob Sendejar (Youth) Janet Zuniga (Youth)
Present Staff:
Sylvia Wilson(Human Relations) Patsy Garcia (Human Relations) Alison Logan (Legal)
Absent Commissioners:
Toni Davis (Excused)
B. REQUESTS FOR EXCUSED ABSENCES
MOTION Motion to excuse Toni Davis for the August 4, 2011 meeting made by Kathleen Cooper and
seconded by Robert Adler. Motion passed.
[Mr. Gamboa asked new Commissioner, Carlos Aguinaga, to introduce himself to the
Commissioners.]
2. APPROVAL OF REGULAR MEETING MINUTES OF 07/07/11
MOTION Motion to approve the July 7, 2011 meeting minutes as written made by Robert Franklin
and seconded by Pastor Reaves. Motion passed.
3. PUBLIC COMMENTS (LIMITED TO 3 MINUTES)
None
4. PRESENTATIONS
A. Emergency Preparedness for Persons with Disabilities —
Billy Delgado, Interim Emergency Management Coordinator
Interim Emergency Management Coordinator, Billy Delgado and Assistant Chief/Fire
Marshall, Andy Cardiel presented a PowerPoint presentation to the Commissioners
regarding the City's Transportation and Evacuation Plan. The following is the
PowerPoint presentation which was presented at the meeting.
SCANNED Page 1 of 25
8/4/2011
"' FUNCTIONAL
I„�.�
NEEDS
EVACUATION
August 3,2011
•
PLANNING MEETINGS
Traffic Engineering
CCFD
CCPD
CCISD Transportation
RTA
211 Texas
Coastal Bend Center for Independent Living
Human Relations
Senior Community Staff
ih
Evacuation Staff
MIS
SPECIALIZED STAFF
Human Relations
Health Department—Nurses I Pet Registration
EMS
CCPD
MIS Support Staff
Public Health
Red Cross
Salvation Army
Functional Needs Support Team
Senior Community Services
1
Page 2 of 25
8/4/201 1
FUNCTIONAL NEEDS
SUPPORT TEAM
Area Agency on Aging
Coastal Bend Center for Independent Living
CC Regional Transportation Authority
Deaf&Hard of Hearing Center
MHMR of Nueces County
Nurses on Wheels,Inc.
South Texas Lighthouse for the Blind
rel.%
Texas A&M University ittr.1
Texas Rural Legal Aid
211 Texas
EVACUATION SCENARIO
OVERVIEW
Floor Plan
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Page 3 of 25
•
8/4/201]
•
EVACUATION PROCESS
• Register at Registration Table.City staff will
enter data onto Functional Needs Evacuation
Tracking System.(Plan B:Enter basic info on
excel spreadsheet)
• Evacuees will receive a numbered ID Bracelet
and luggage tag for items stowed below the
bus.
• Evacuees transporting pets go to designated
area and Animal Care personnel will triage pet,
then proceed with Registration.All pets must
be secured.
• Numbered boarding bus pass will be issued.
,1 Pt 0• g Y'entry to center.
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Page 4 of 25
•
8/4/2011
WAITING AREA/
GYM OPEN AREA
• Water will be available for distribution
to evacuees.
• Evacuees will be escorted to sit in their
designated area. They will be seated
based on boarding passes issued at
registration.
I ,S
Wrist bard Beta : t ,.n laptop with j
evacuee v � ati•
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NEtrr4%.4 {,. (
BOARDING THE BUS
• Evacuees will be called to board the bus by staff.
• Fire Prevention Staff will scan wristbands on
evacuees as they are boarding the bus.City
Staff will assist in carrying their belongings to
bus,as needed.(Plan B:manually write the
names of bus passengers as manifest)
• City Staff will assist with stowing items on the
bus.
• City Staff will provide Bus Driver with a manifest
of riders on board.
• Snack bags will be distributed to evacuees while
boarding the bus.Snack bags will be distributed
by the Salvation Army.
4
Page 5 of 25
8/4/2011
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Page 6 of 25
5. CHAIRPERSON'S REPORT
A. Discussion/Approval of CCPD Parking Control Enforcement Actions Resolution
Sylvia Wilson stated at the CFPWD meeting, there was a concern in reference to the
use of the word "disabled" and the Committee asked the Legal Department to research
if the use of the word "disabled" should be replaced by "accessible" in the resolution.
After the department receives a response from the Legal Department, the resolution will
be updated if needed.
Motion to table item 5.A. Discussion/Approval of CCPD Parking Control Enforcement
MOTION Actions Resolution until the September 1 , 2011 meeting made by Pastor Derrick
Reaves and seconded in unison. Motion passed.
B. Proposed Changes to Amend Section 24-55 of the Code of Ordinances Regarding
Administrative Penalties Pertaining to Housing Discrimination
MOTION Motion to change the monetary status on the administrative penalties pertaining to
housing discrimination made by Jacob Sendejar and seconded by Elias Valverde.
Motion passed.
MOTION Motion to change the title of "Director" to "Administrator" in the Code of Ordinances
made by Denise Villagran and seconded in unison. Motion passed.
Sylvia Wilson reported the City Council approved the budget. The budget presented on
behalf of the Human Relations Department included the "Director" title/position be
removed and replaced with an "Administrator" title/position. Human Relations is no
longer a department, rather, it is now a division of the Legal Department. The division
reports directly to the City Attorney.
C. Discussion/Action Pertaining to U.S. Department of Housing and Urban
Development Fair Housing Investigations Case Numbers 061004878, 061100258,
061100558, request for Subpoena
June Martinez provided a brief overview of Respondents failure to comply with
subpoena. A summary of steps taken since subpoena issuance was provided by Mrs.
Martinez. Staff requested approval for a Court Petition "Motion to Compel". It was
granted.
D. The Dream Act Update
Sylvia Wilson stated there was a request given to her from the City Secretary's Office
on behalf of the Mayor to place the resolution in support of The Dream Act to be placed
on the Tuesday, August 23, 2011 City Council Agenda. Mrs. Wilson invited the
Commissioners to attend the meeting in support of The Dream Act.
Page 7 of 25
•
6. SUBCOMMITTEE REPORTS
A. Housing Subcommittee — No Report
B. Committee for Persons With Disabilities — Meeting of 08/03/11
Sylvia Wilson reported the following:
• Announcement by the Employment Alliance for People with Disabilities - There will be
a presentation at the September 2011 CFPWD Monthly Meeting regarding a job fair
which will be held during the month of October 2011 focusing on promoting the
employment attributes of persons with disabilities. Mrs. Wilson recommended the item
also be placed on the Commission's September 2011 Monthly Meeting agenda.
• Presentation by Jamie Pyle, Engineering Department — Ms. Pyle provided an update
on the ADA Improvements Group 1 , Group 2, and Group 3. Mrs. Wilson
recommended the item also be placed on the Commission's September 2011 Monthly
Meeting agenda.
C. Education Subcommittee — No Report
Kathleen Cooper stated she did not have a report. However, indicated she and Youth
Commissioner, Janet Zuniga, are going to continue working on trying to get Texas A&M
to allow them to get on board and allow the Youth Commissioners to do some
presentations regarding youth at work and employee rights. Ms. Cooper stated she will
have a report at next month's meeting.
D. Disparity Subcommittee — No Report
Mr. Gamboa stated he is planning on including a presentation item on the agenda for
the September Monthly Meeting.
E. Health Disparity Subcommittee — Discussion/Action to Dissolve the Health
Disparity Subcommittee
Due to no updates or reports within the last year, and with the approval of the
Commissioners, Mr. Gamboa recommended dissolving the Health Disparity
Subcommittee.
MOTION Motion to Dissolve the Health Disparity Subcommittee made by Robert Franklin and
seconded by Robert Adler. Motion passed.
7. HUMAN RELATIONS ADMINISTRATOR'S REPORT
A. Department Monthly Performance Report Review
Sylvia Wilson provided the Commissioners with copies of the July 2011 Monthly
Performance Report. Highlights were shared with the Commissioners.
June Martinez provided a brief overview of a cause proposed case and distributed a
copy of the VAWA (Violence Against Women Act) HUD Guidance. The CCHRC agreed
with recommendations and authorized issuance of formal complaint and notices
according to the City's Code of Ordinances procedures.
Motion to proceed with the cause case proposal to advance to the formal issuance of
MOTION the housing complaint made by Jacob Sendejar and seconded by Janet Zuniga.
Motion passed.
Page 8 of 25
IIL!MAN RELATIONS
MISSION AND SERVICE STRATEGY;
With a goal of"Fostering Diverse and Equitable Environments With Respect and Professionalism",the Human Relations Department will
conduct and enforce a positive program of non-discrimination in Employment,Fair I lousing,Public Accommodation,and Compliance
with the Americans with Disabilities Act(ADA)within the('ity of Corpus Christi. We will also make reports and recommendations to
the City Council and others,toward the betterment of gaup and inter_grou�relationships within the amununity_
MAJOR PROGRAMS AND SERVICES:
A. Non-Discrimination Program
I.Intake,Investigative,and Mediation/Resolution Services
2.Community Outreach,Education,and Awareness
3.Technical and Administrative Services
It. ADA Compliance
I Address and monitor ADA compliance,and related issues,through accommodation requests and citizen complaints;
Community Education and Awareness;and Technical/Administrative Assistance.
2.Coordination of implementation,monitoring,and update of the Citywide ADA Transition Plan
PERFORMANCE MEASURE OBJECTIVES Adopted April ay lune July YTD
2010-2011 Prior Month I Jl
Prior MonthI Prior.Down !Current Month 2010-2011
A. SERVICE LEVET,OBJECTIVE:
Provide Investigative Service to include intake,investigation,mediation,conc.,liation,monitoring,and charge resolution in
Employment(including ADA),Fair I lousing,and Public Accommodation.
Measures: Output
EEOC Contract Yr Closures Goal -
Total and%of Goal- 10/1 to 9/30 i i u i' 4 4 14 4 62(62%)
Total Intake Goal(Referred to EEOC) -
Total and%of Goal-10/I to 9/30 98. 8 ti' 17 I() 83(85%)
I-Il1D Fair Housing Complaint Resolution -
Total -7/I/to 6/30 42 I t 8 2 42(100%)
Measures :Et tectivenesss
EEOC Charge Write-Ups(Per crone Charges)comp eted —
and sent to SATO in 8 days or less(as%of) 90% 4/8(50%) t > 4(4 s"i,) 43/82(55%)
EEOC Charges Closed within 180 days as%of total
closures YTD-10/1 to 9/30 75% 2/4(50%) 2 5 I 37/62(60%)
I IUD Fair I lousing Complaints closed
within 100 days as'A of total 70% _ I/1(100) 3/3(100%) 4' I 10 42(72%)
It. SERVICE LEVEL OBJECTIVE:
Provide"Community Outreach,Education,and Awaren,.2ss"
,lleasures: Output
Number of training sessions,community meetings,and
informational events-8/1/to 7/31 40 I 2 2 r, 4y
C. SERVICE LEVEL,OBJECTIVE:
Provide ADA Accessibility,Accommodations,and Technical Assistance Revues(r,-,,Iiiii ii
Measures: Output -
ADA Citizens'Complaints(Accessibility) 100 ; I t SO
Public Accommodation Requests 55 1 2 8 30
ADA Trash Service Assistance 20 2 4 55
ADA Technical Assistance 40 .. I 2 7 86
Plan Reviews/Site Visits 4 I I 3 30
Key Highlights:
EEOC Downgrade:Due to 3rd Qtr status of 62/u vs preferred .
Jul
° goal, from 100 to 90.
75/o of 100 case down modification has been made
Trying to close 30 cases by end of Sept.,
Most significant matter in July was the rush of 41 complaints received:14 in first week;15 second week;9 third week and 3 fourth week
June Martinez will be present case summaries on#06-10-0422-8)g)and 06-10-0487-8(H)and request continuation of legal action
involving Federal District Court involvement.
Page 9 of 25
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U.S.DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
*tillGI *�° WASHINGTON,DC 20410-2000
OFfl1 F FAIR HOUSING February 9, 2011
AND EQUAL OPPORTUNITY
MEMORANDUM FOR: FHEO Office Directors
FHEO Regional Directors
FROM: S. . 773' _ P-.• Ae�f l:�ti` cretary for Enforcement and
''roa . Is
SUBJECT: Assessing Claims of Housing Discrimination against Victims of
Domestic Violence under the Fair Housing Act(FHAct)and the
Violence Against Women Act(VAWA)
I. Purpose
This memorandum provides guidance to FHEO headquarters and field staff on assessing
claims by domestic violence victims of housing discrimination under the Fair Housing Act(FHAct).
Such claims are generally based on sex,but may also involve other protected classes,in particular
race or national origin. This memorandum discusses the legal theories behind such claims and
provides examples of recent cases involving allegations of housing discrimination against domestic
violence victims. This memorandum also explains how the Violence Against Women Act
(VAWA)' protects some domestic violence victims from eviction,denial of housing,or termination
of assistance on the basis of the violence perpetrated by their abusers.
II. Background
Survivors of domestic violence often face housing discrimination because of their history or
the acts of their abusers. Congress has acknowledged that"[w]omen and families across the
country are being discriminated against,denied access to,and even evicted from public and
subsidized housing because of their status as victims of domestic violence."2 Housing authorities
and landlords evict victims under zero-tolerance crime policies,citing the violence of a household
member, guest,or other person under the victim's"control."3 Victims are often evicted after
repeated calls to the police for domestic violence incidents because of allegations of disturbance to
other tenants. Victims are also evicted because of property damage caused by their abusers. In
This guidance refers to the Violence Against Women and Department of Justice Reauthorization Act of 2005(VAWA
2005),which included provisions in Title VI("Housing Opportunities and Safety for Battered Women and Children")
that are applicable to HUD programs. The original version of VAWA,enacted in 1994,did not apply to HUD programs.
Note also that HUD recently published its VAWA Final Rule. See HUD Programs:Violence Against Women Act
Conforming Amendments;Final Rule,75 Fed.Reg.66246(October 27,2010).
242 U.S.C. § I 4043e(3)(findings published in the Violence Against Women Act). Note that VAWA also protects male
victims of domestic violence. See HUD Programs:Violence Against Women Act Conforming Amendments;Final
Rule,75 Fed.Reg. 66246,66251 ("VAWA 2005 does protect men. Although the name of the statute references only
women,the substance of the statute makes it clear that its protections are not exclusively applicable to women.").
3 See 24 CFR§ 5.100.
Page 10 of 25
many of these cases,adverse housing action punishes victims for the violence inflicted upon them.
This"double victimization"4 is unfair and,as explained in this guidance,may be illegal.
Statistics show that women are overwhelmingly the victims of domestic violence.5 An
estimated 1.3 million women are the victims of assault by an intimate partner each year, and about 1
in 4 women will experience intimate partner violence in their lifetimes.6 The U.S.Bureau of Justice
Statistics found that 85%of victims of domestic violence are women. In 2009,women were about
five times as likely as men to experience domestic violence.8 These statistics show that
discrimination against victims of domestic violence is almost always discrimination against women.
Thus,domestic violence survivors who are denied housing, evicted,or deprived of assistance based
on the violence in their homes may have a cause of action for sex discrimination under the Fair
Housing Act.9
In addition,certain other protected classes experience disproportionately high rates of
domestic violence. For example,African-American and Native American women experience
higher rates of domestic violence than white women. Black women experience intimate partner
violence at a rate 35%higher than that of white females,and about 2.5 times the rate of women of
other races.10 Native American women are victims of violent crime,including rape and sexual
assault, at more than double the rate of other racial groups.t t Women of certain national origins and
immigrant women also experience domestic violence at disproportionate rates.12 This means that
victims of domestic violence may also have a cause of action for race or national origin
discrimination under the Fair Housing Act.
III. HUD's"One Strike"Rule and The Violence Against Women Act(VAWA)
In 2001,the Department issued a rule allowing housing authorities and landlords to evict
tenants for criminal activity committed by any household member or guest,commonly known as the
"one strike"rule.13 The rule allows owners of public and Section 8 assisted housing to terminate a
tenant's lease because of criminal activity by"a tenant, any member of the tenant's household, a
`See Lenora M.Lapidus,Doubly Victimized:Housing Discrimination Against Victims ofDomestic Violence, 11 J.
GENDER,Soc.P0L'Y&L.377(2003).
s We recognize that men also experience domestic violence. However,because of the wide disparity in victimization,
and because many FHAct claims will be based on the disparate impact of domestic violence on women,we use feminine
pronouns throughout this guidance.
Centers for Disease Control and Prevention,National Center for Injury Prevention and Control,Costs of Intimate
Partner Violence Against Women in the United States(2003).
U.S.Department of Justice,Office of Justice Programs,Bureau of Justice Statistics Crime Data Brief,Intimate Partner
Violence, 1993-2001(2003).
9 Jennifer R.Truman&Michael R.Rand,U.S.Department of Justice,Criminal Victimization,2009(2010).
Domestic violence by same-sex partners would be analyzed in the same manner and would be based on sex and any
other applicable protected classes.
10 Id
"Steven W.Perry,U.S.Dep't of Justice,NCJ 203097,A Bureau ofJustice Statistics Statistical Profile, 1992-2002:
American Indians and Crime(2004).
12 For statistics on specific groups,see American Bar Association Commission on Domestic Violence,Survey of Recent
Statistics,http://new.abanet.org/domesticviolence/Pazes/Statistics.aspx.
13 Screening and Eviction for Drug Abuse and Other Criminal Activity,66 Fed.Reg.28776(May 24,2001)(amending
24 CFR pts.5,200,247,880,884,891,960,966,and 982)(often referred to as the"one strike"rule).
2
Page 11 of 25
guest or another person under the tenant's controli14 that'threatens the health,safety,or right to
peaceful enjoyment of the premises by other residents(including property management staff
residing on the premises);or... threatens the health,safety, or right to peaceful enjoyment of their
residences by persons residing in the immediate vicinity of the premises."15 This policy would
seem to allow evictions of women for the violent acts of their spouses,cohabiting partners,or
visitors. However,the Violence Against Women and Department ofJustice Reauthorization Act of
2005(VAWA)16 prohibits such evictions in public housing,voucher,and Section 8 project-based
programs. VAWA protects victims of domestic violence,dating violence,sexual assault, and
stalking.t 7
VAWA provides that being a victim of domestic violence,dating violence,or stalking is not
a basis for denial of assistance or admission to public or Section 8 tenant-based and project-based
assisted housing. Further, incidents or threats of abuse will not be construed as serious or repeated
violations of the lease or as other"good cause"for termination of the assistance, tenancy, or
occupancy rights of a victim of abuse. Moreover,VAWA prohibits the termination of assistance,
tenancy, or occupancy rights based on criminal activity directly relating to domestic violence,dating
violence, or stalking,engaged in by a member of a tenant's household or any guest or other person
under the tenant's control if the tenant or immediate member of the tenant's family is a victim of
that domestic violence, dating violence,or stalking.18
VAWA also allows owners and management agents to request certification from a tenant
that she is a victim of domestic violence,dating violence,or stalking and that the incidence(s) of
threatened or actual abuse are bona fide in determining whether the protections afforded under
VAWA are applicable.t9 The Department has issued forms for housing authorities and landlords to
use for such certification requests,20 but tenants may also present third-party documentation of the
1424 CFR§ 5.100.
15 24 CFR§5.859.
16 Pub.L. 109-162, 119 Stat.2960(2006). For the Department's final rule on VAWA,see HUD Programs:Violence
Against Women Act Conforming Amendments;Final Rule,75 Fed.Reg.66246(Oct.27,2010)(amending 24 CFR pts.
5,91,880,882,883,884,886,891,903,960,966,982,and 983).
17 Each of these terms is defined in VAWA and HUD's corresponding regulations. See HUD Programs:Violence
Against Women Act Conforming Amendments;Final Rule,75 Fed.Reg.66246,66258.
lr Note the exception to these provisions at 24 C.F.R.§5.2005(d)(2),which states that VAWA does not limit the
authority of a PHA,owner,or management agent to evict or terminate a tenant's assistance if they can demonstrate an
actual and imminent threat to other tenants or those employed or providing services at the property if that tenant is not
terminated. However,this exception is limited by§5.2005(d)(3),which states that a PHA,owner,or management agent
can terminate assistance only when there are no other actions that could reduce or eliminate the threat.Other actions
include transferring the victim to different unit,barring the perpetrator from the property,contacting law enforcement to
increase police presence or developing other plans to keep the property safe,or seeking other legal remedies to prevent
the perpetrator from acting on a threat.
"42 U.S.C. §1437d(u)(1)(A)(public housing program),42 U.S.C.§1437f(ee)(1)(voucher programs).
Z0 HUD Housing Notice 09-1S transmits Form HUD-91066,Certification of Domestic Violence,Dating Violence or
Stalking for use by owners and management agents administering one of Multifamily Housing's project-based Section 8
programs and Form HUD-91067,the HUD-approved Lease Addendum,for use with the applicable HUD model lease
for the covered project-based Section 8 program. HUD Public and Indian Housing Notice 2006-42 transmits form
HUD-50066,Certification of Domestic Violence,Dating Violence or Stalking,for use in the Public Housing Program,
Housing Choice Voucher Program(including project-based vouchers),Section 8 Project-Based Certification Program,
and Section 8 Moderate Rehabilitation Program. See also PIH Notice 2006-23,Implementation of the Violence Against
Women and Justice Department Reauthorization Act of 2005.
3
Page 12 of 25
abuse,including court records,police reports,or documentation signed by an employee, agent,or
volunteer of a victim service provider,an attorney, or a medical professional from whom the victim
has sought assistance in addressing the abuse or the effects of the abuse.21 Finally,VAWA allows
housing authorities and landlords to bifurcate a lease in a domestic violence situation in order to
evict the abuser and allow the victim to keep her housing.22
While VAWA provides important protections for victims of domestic violence,it is limited
in scope. For example,it does not provide for damages z3 In addition, VAWA does not provide an
explicit private cause of action to women who are illegally evicted. Moreover, VAWA only
protects women in public housing, voucher,and Section 8 project-based programs, so domestic
violence victims in private housing have no similar protection from actions taken against them
based on that violence. VAWA also may not protect a woman who does not provide the requisite
documentation of violence,24 while a claim of discrimination under the Fair Housing Act is not
dependent on compliance with the VAWA requirements. In short,when a victim is denied housing,
evicted,or has her assistance terminated because she has been a victim of domestic violence, the
FHAct might be implicated and we may need to investigate whether that denial is based on, for
example,race or sex.
IV. Legal Theories under the Fair Housing Act: Direct Evidence, Unequal Treatment,and
Disparate Impact
Direct evidence. In some cases,landlords enforce facially discriminatory policies. These
policies explicitly treat women differently from men. Such policies are often based on gender
stereotypes about abused women. For example,if a landlord tells a female domestic violence
victim that he does not accept women with a history of domestic violence as tenants because they
always go back to the men who abuse them,his statement is direct evidence of discrimination based
on sex. Investigations in direct evidence cases should focus on finding evidence about whether or
not the discriminatory statement was made,whether the statement was applied to others to identify
other potential victims, and whether it reflects a policy or practice by the landlord. The usual
questions that address jurisdiction also apply.
Unequal treatment. In some cases,a landlord engages in unequal treatment of victims of
domestic violence in comparison to victims of other crimes. Or a landlord's seemingly gender-
neutral policy may be unequally applied,resulting in different treatment based on sex. For example,
a policy of evicting households for criminal activity may be applied selectively against women who
have been abused by their partners and not against the male perpetrators of the domestic violence.
If there is evidence that women are being treated differently because of their status as victims of
domestic violence,an unequal treatment theory applies. If an investigator finds evidence of unequal
treatment, the investigation shifts to discovering the respondent's reasons for the differences and
2142 U.S.C.§1437d(u)(1)(C);42 U.S.C.§ 1437f(ee)(1)(c).
22 42 U.S.C.§1437d(1)(6)(B);42 U.S.C.§ 1437f(c)(9)(C).
23 Remedies available under VAWA include,for example,the traditional P11-I grievance process. See HUD Programs:
Violence Against Women Act Conforming Amendments;Final Rule,75 Fed.Reg.66246,66255.
24 While VAWA 2005 allows owners and PHAs to request certification of domestic violence from victims,the law also
provides that owners and PHAs"[aJt their discretion. ..may provide benefits to an individual based solely on the
individual's statement or other corroborating evidence." 42 U.S.C.A. § 1437d(u)(1)(D);42 U.S.C.A.
§ 1437(f)(ee)(1)(D).
4
Page 13 of 25
•
investigating each reason to determine whether the evidence supports or refutes each reason. If a
nondiscriminatory reason(s)is articulated,the investigation shifts again to examining the evidence
to determine whether or not the reason(s)given is supported by the evidence or is a pretext for
discrimination.25
Disparate impact. In some cases, there is no direct evidence of unequal treatment,but a
facially neutral housing policy,procedure,or practice disproportionately affects domestic violence
victims. In these cases,a disparate impact analysis is appropriate. Disparate impact cases often
arise in the context of"zero-tolerance"policies,under which the entire household is evicted for the
criminal activity of one household member. The theory is that,even when consistently applied,
women may be disproportionately affected by these policies because,as the overwhelming majority
of domestic violence victims,women are often evicted as a result of the violence of their abusers.
There are four steps to a disparate impact analysis. First,the investigator must identify the
specific policy,procedure,or practice of the landlord's that is allegedly discriminatory. This
process means both the identification of the policy,procedure,or practice and the examination of
what types of crimes trigger the application of the policy. Second, the investigator must determine
whether or not that policy,procedure,or practice was consistently applied. This step is important
because it reveals the correct framework for the investigation. If the policy is applied unequally,
then the proper analysis is unequal treatment,not disparate impact. If,however, the policy was
applied consistently to all tenants,then a disparate impact analysis applies,and the investigation
proceeds to the next step.
Third, the investigation must determine whether or not the particular policy,procedure,or
practice has a significant adverse impact on domestic violence victims and if so,how many of those
victims were women(or members of a certain race or national origin). Statistical evidence is
generally used to identify the scope of the impact on a group protected against discrimination.
These statistics should be as particularized as possible;they could demonstrate the impact of the
policy as to applicants for a specific building or property,or the impact on applicants or residents
for all of the landlord's operations. For example,in a sex discrimination case,the investigation may
uncover evidence that women in one apartment complex were evicted more often than men under a
zero-tolerance crime policy. It would not matter that the landlord did not intend to discriminate
against women,or that the policy was applied consistently. Proof of disparate impact claims is not
an exact science. Courts have not agreed on any precise percentage or ratio that conclusively
establishes a prima facie case. Rather,what constitutes a sufficiently disparate impact will depend
on the particular facts and circumstances of each case.
If the investigation reveals a disparate impact based on sex,race,or national origin,the
investigation then shifts to eliciting the respondent's reasons for enforcing the policy. It is critical to
thoroughly investigate these reasons. Why was the policy enacted? What specific outcome was it
meant to achieve or prevent? Were there any triggering events? Were any alternatives considered,
and if so, why were they rejected? Is there any evidence that the policy has been effective? What
constitutes a sufficient justification will vary according to the circumstances. In general, the
investigation will examine whether or not the offered justification is real and supported by a
substantial business justification. For the purposes of this memorandum,it is important to
'S See McDonnell Douglas Corp. v.Green,411 U.S.792(1973)for an explanation of the burden-shifting formula.
5
Page 14 of 25
understand that an investigation must identify and evaluate the evidence supporting and refuting the
justification.
Even if there is sufficient justification for the policy, there may be a less discriminatory
alternative available to the respondent. A disparate impact investigation must consider possible
alternative policies and analyze whether each policy would achieve the same objective with less
discriminatory impact. For example, in a case of discriminatory eviction under a zero-tolerance
policy, a landlord could adopt a policy of evicting only the wrongdoer and not innocent victims.
This policy would protect tenants without unfairly penalizing victims of violence.
In summary, an investigation of a disparate impact case must seek evidence that a specific
policy of the landlord's caused a substantial,disproportionate, adverse impact on a protected class
of persons. Proving a disparate impact claim will generally depend on statistical data demonstrating
the disparity and a causal link between the policy and the disparity;discriminatory intent is
irrelevant.
V. Fair Housing Cases Involving Domestic Violence
Eviction Cases. Victims are often served with eviction notices following domestic violence
incidents. Landlords cite the danger posed to other tenants by the abuser,property damage
caused by the abuser, or other reasons for eviction. Several cases have challenged these
evictions as violations of VAWA or the Fair Housing Act.
Alvera v. CBM Group, Case No. 01-857(D. Or.2001).26 The victim was assaulted by her
husband in their apartment. She obtained a restraining order against her husband, and he was
subsequently arrested and jailed for the assault. She provided a copy of the restraining order to the
property manager. The property manager then served her with a 24-hour eviction notice based on
the incident of domestic violence. The notice specified: "You,someone in your control,or your pet,
has seriously threatened to immediately inflict personal injury, or has inflicted personal injury upon
the landlord or other tenants." The victim then submitted an application for a one-bedroom
apartment in the same building. Management denied the application and refused to accept her rent.
After a second application,management finally approved her for a one-bedroom apartment, but
warned her that"any type of recurrence"of domestic violence would lead to her eviction.
The victim filed a complaint with HUD, which investigated her case and issued a charge of
discrimination against the apartment management group. She elected to pursue the case in federal
court. The parties later agreed to settle the lawsuit. The consent decree,approved by the Oregon
district court in 2001, requires that the management group agree not to"evict,or otherwise
discriminate against tenants because they have been victims of violence, including domestic
violence"and change its policies accordingly. Employees of the management group must
participate in education about discrimination and fair housing law. The management group also
agreed to pay compensatory damages to the victim.
Warren v. Ypsilanti Housing Authority, Case No. 4:02-cv-40034(E.D. Mich.2003). The
victim's ex-boyfriend broke into her house and physically abused her. She called the police to
26 A copy of the determination is attached to this memo.
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Page 15 of 25
report the attack. When the Ypsilanti Housing Authority(YHA)learned of the attack, it attempted
to evict the victim and her son under its zero-tolerance crime policy. The ACLU sued the YHA for
discrimination,arguing that because victims of domestic violence are almost always women, the
policy of evicting domestic violence victims based on the violence perpetrated against them had a
disparate impact based on sex in violation of the federal Fair Housing Act and state law. The parties
reached a settlement, under which the YHA agreed to cease evicting domestic violence victims
under its "one-strike"policy and pay money damages to the victim.
Bouley v. Young-Sabourin 394 F. Supp.2d 675(D. Vt.2005). The victim called the police after
her husband attacked her in their home. She obtained a restraining order against her husband and
informed her landlord. The landlord spoke to the victim about the incident,encouraging her to
resolve the dispute and seek help through religion. The victim told her landlord that she would not
let her husband return to the apartment and was not interested in religious help. The landlord then
served her with a notice of eviction,stating that it was`blear that the violence would continue." In a
ruling on the parties' cross-motions for summary judgment,the court held that the victim had
presented a prima facie case of sex discrimination under the Fair Housing Act. The case later
settled.
T.J. v. St.Louis Housing Authority(2005). The victim endured ongoing threats and harassment
after ending her relationship with her abusive boyfriend. He repeatedly broke the windows of her
apartment when she refused to let him enter. She obtained a restraining order and notified her
landlord, who issued her a notice of lease violation for the property damage caused by the ex-
boyfriend and required her to pay for the damage,saying she was responsible for her domestic
situation. Her boyfriend finally broke into her apartment and,after she escaped,vandalized it. The
housing authority attempted to evict her based on this incident. The victim filed a complaint with
HUD,which conciliated the case. The conciliation agreement requires the housing authority to
relocate her to another apartment,refund the money she paid for the broken windows,ban her ex-
boyfriend from the property where she lived,and send its employees to domestic violence
awareness training.
Lewis v. North End Village,Case No. 2:07-cv-10757(E.D.Mich. 2007). The victim obtained a
personal protection order against her abusive ex-boyfriend. Months later,the ex-boyfriend
attempted to break into the apartment,breaking the windows and front door. The management
company that owned her apartment evicted the victim and her children based on the property
damage caused by the ex-boyfriend. With the help of the ACLU of Michigan,she filed a complaint
against the management company in federal court, alleging sex discrimination under the FHAct.
The case ultimately settled, with the management company agreeing to new,nondiscriminatory
domestic violence policies and money damages for the victim.
Brooklyn Landlord v. R.F. (Civil Court of Kings County 2007). The victim's ex-boyfriend
continued to harass,stalk, and threaten her after she ended their relationship. In late April 2006,he
came to her apartment in the middle of the night, banging on the door and yelling. The building
security guard called by the victim was unable to reason with her abuser,who left before the police
arrived. One week later, the abuser came back to the building, confronted the same security guard,
and shot at him. The victim was served an eviction notice from her Section 8 landlord based on this
incident. The victim filed a motion for summary judgment which asserted defenses to eviction
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Page 16 of 25
•
under VAWA and argued that the eviction constituted sex discrimination prohibited by the FHAct.
The parties reached a settlement under which the landlord agreed to take measures to prevent the
ex-boyfriend from entering the property.
Jones v.Housing Authority of Salt Lake County(D.Utah,filed 2007). The victim applied for
and received a Section 8 voucher in 2006. She and her children moved into a house in Kearns, Utah
later that year. She allowed her ex-husband,who had previously been abusive, to move into the
house. Shortly after he moved in,the victim discovered that he had begun drinking again. After he
punched a hole in the wall, the victim asked him to move out. When he refused,she told the
Housing Authority that she planned to leave the home with her children to escape the abuse. The
Housing Authority required her to sign a notice of termination of her housing assistance. The
victim requested a hearing to protest the termination,and the Housing Authority decided that
termination of her assistance was appropriate,noting that she had never called the police to report
her husband's violent behavior. With the help of Utah Legal Services,she filed a complaint in
federal court against the Housing Authority, alleging that the termination of her benefits violated
VAWA and the FHAct.
Cleaves Milan v. AIMCO Elm Creek LP, 1:09-cv-06143 (N.D. Ill., filed October 1,2009). In
2007,the victim moved into an Elmhurst,Illinois apartment complex with her fiancé and her
daughter. Her fiancé soon became abusive, and she ended the relationship. He became upset,
produced a gun,and threatened to shoot himself and her. She called police to remove him,obtained
an order of protection, and removed him from the lease with the consent of building management.
When she attempted to pay her rent,however,building management told her that she was being
evicted because"anytime there is a crime in an apartment the household must be evicted." With the
help of the Sargent Shriver National Center on Poverty Law, she filed a complaint against the
management company for sex discrimination under the Fair Housing Act.
Transfer Cases. Victims will also sometimes request transfers within a housing authority in
order to escape an abuser. Two recent cases have challenged the denial of these transfers as sex
discrimination under the Fair Housing Act,with mixed results.
Blackwell v. H.A. Housing LP, Civil Action No. 05-cv-01225-LTB-CBS(D. Colo. 2005). The
victim's ex-boyfriend broke into her apartment and,over the course of several hours,raped,beat,
and stabbed her. She requested a transfer to another complex. Building management refused to
grant her the transfer, forcing her and her children into hiding while police pursued her ex-
boyfriend. With the help of Colorado Legal Services,the victim filed a complaint in federal court,
alleging that the failure to grant her transfer request constituted impermissible discrimination on the
basis of sex based on a disparate impact theory. The case eventually settled. The landlord agreed to
institute a new domestic violence policy,prohibiting discrimination against domestic violence
victims and allowing victims who are in imminent physical danger to request an emergency transfer
to another Section 8 property.
Robinson v. Cincinnati Metropolitan Housing Authority, Case No. 1:08-CV-238(S.D.Ohio
2008). The victim moved into a Cincinnati public housing unit with her children in 2006.She
began dating a neighbor,who physically abused her repeatedly. When she tried to end the
relationship, he beat her severely and threatened to kill her if she ever returned to the apartment.
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Page 17 of 25
She obtained a protection order and applied to the Cincinnati Metropolitan Housing Authority
(CMHA)for an emergency transfer,but was denied. The victim was paying rent on the apartment
but lived with friends and family for safety reasons. With the help of the Legal Aid Society of
Southwest Ohio,the victim filed a complaint against CMHA in federal court, alleging that by
refusing to grant her occupancy rights granted to other tenants based on the acts of her abuser,
CMHA intentionally discriminated against heron the basis of sex. The court denied her motion for
a temporary restraining order and preliminary injunction, finding that CMHA policy allows
emergency transfers only for victims of federal hate crimes,not for victims of domestic violence.
The court also distinguished cases of domestic violence-based eviction from the victim's case,27
saying that CMHA did not violate her rights under the FHAct by denying her a transfer.
VI. Practical Considerations When Working with a Victim of Domestic Violence
When working with a victim of domestic violence,an investigator must be sensitive to.the
victim's unique circumstances. She is not only a potential victim of housing discrimination,she is
also a victim of abuse. Often, a victim who is facing eviction or other adverse action based on
domestic violence also faces urgent safety concerns. She may fear that the abuser will return to
harm her or her children. An investigator should be aware of resources available to domestic
violence victims and may refer a victim to an advocacy organization or to the police.28 Investigators
should also understand that a victim may be hesitant to discuss her history. Victims are often
distrustful of"the system"after negative experiences with housing authorities,police,or courts. In
order to conduct an effective investigation, investigators should be patient and understanding with
victims and try not to appear judgmental or defensive.29
VII. Conclusion
The Violence Against Women Act provides protection to some victims of domestic violence
who experience housing discrimination but it does not protect them from discrimination based on
sex or another protected class. Thus,when a victim is denied housing,evicted,or has her assistance
terminated because she has experienced domestic violence, we should investigate whether that
denial or other activity violates the Fair Housing Act. Victims may allege sex discrimination,but
may also allege discrimination based on other protected classes,such as race or national origin.
Questions regarding this memorandum should be directed to Allison Beach,Office of the
Deputy Assistant Secretary for Enforcement and Programs, at(202)619-8046,extension 5830.
27 In its order denying Robinson's request for a temporary restraining order and a preliminary injunction,the court cites
Gouley,Lewis, Warren,and Alvera as cases that"recognized that to evict the women in these situations had the effect of
victimizing them twice:first they are subject to abuse and then they are evicted." Order at 6.
28 Nationwide resources include the National Domestic Violence Hotline,at l-800-799-SAFE(7233)or
www.thehotline.org,and www.womenslaw.org. Either resource can refer victims to local advocates and shelters and
provide safety planning advice.
For more advice on working with domestic violence survivors,see Loretta M.Frederick,Effective Advocacy on Behalf
of Battered Women,The Battered Women's Justice Project,available at
litto://www.bwimorgitiles/bwip/articlesiEffective Advocacy_Battered Women.pdt:
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Page 18 of 25
CASE NAME: Alvera v Creekside Village Apartments
CASE NUMBER: 10-99-0538-8
•
I. JI RISDICTION
A complaint was filed with the Department-on October 22, 1999, alleging that Ms.
Tiffani Ann.Alvera,the complainant,was injured by a discriminatory act by the
respondents, Creekside Village Apartments,,a California Limited Partnership;General
Partners Edward and Dorian Mackay;The CBM Group,Inc.; and CBM Group employees
Karen Mock, Resident Manager of Creekside Village Aparunents, and Inez Corencvsky,
Supervising Property Manager. It is alleged that the respondents were responsible for a ,
discriminatory refusal to rent and discriminatory terms, conditions,privileges, or services
and facilities, in violation of Sections 804.(a) and (b) of the Fair Housing Act. The most
recent discriminatory act was alleged to have occurred on September 7, 1999. The
property is Creekside Village Apartments, 1953 Spruce Drive, Seaside, Oregon. The
property i c not exempt under the Act,
The respondents receive federal financial-assistance from the United States Department of
Agriculture, Rural*Devcloprnent.
•
II. COMPLAINAN.T'S ALLEGATIONS
•
Ms. Alvera alleged that on August 2, 1999, her husband physically assaulted her in their
home, apartment 21 in Creekside Village Apartments. Her husband was jailed and Ms.
Alvera obtained a temporary restraining order against him. �a management ugust 4,
199that9,tMs.ated that,
Alvera alleged, she received a 24 hour notice to vacate fromg
pursuant to Oregon law "You, someone in your control,or your pet,has seriously
threatened immediately to inflict personal injury, or has inflicted substantial personal
injury upon the landlord or other tenants." The notice specified that the incident was the
assault on Ms. Alvera by her husband. Ms. Alvera alleged further that after issuing the
notice, the managers refused to accept her rent for September. The managers also refused
to move her to a one bedroom apartment; since her husband was not to live with her any
more, she believed that she no longer qualified for a two bedroom apartment in this
USDA subsidized complex. Ms. Alvera alleged that management discriminated against
her because of her sex because the way they interpret and enforce Oregon state law
toward domestic violence victims has a greater negative impact on women. She also
alleged that management would not have treated men the same way as she was treated.
Page 19 of 25
III. RESPONDENTS' DEFENSES
The respondents defended that they gave Ms. Alvera a 24 hour notice to vacate because it
is their policy to evict tenants who pose a threat to the safety and well-being of other
tenants in the complex. When one person in the household poses a threat, the entire
household is evicted_ -
IV. FINDINGS AND CONCLUSIONS - -
The investigation revealed that the subject property consists of forty units and is funded
by the USDA Rural Development program. The property is intended to serve lower
income residents. -
The investigation found,that Ms. Alvera and her former husband, Mr. Tumberto Mota,
signed a lease and.moved-into a two bedroom unit at the complex in November, 1998.
Until the incident from which this complaint arises, Ms. Alvera received no warnings or
admonitions concerning her tenancy from the respondents. During this period Mr. Mota
assaulted Ms. Alvera, who called the police. However,"the respondents apparently were
not aware of this incident and no action was taken with respect to their tenancy. In
March, -1999, respondent Karen Mock became the resident manager ofCreekside Village
Apartments.
•
The evidence shows that on August 2,:1999, at approximately 5:30 am,,Mr. Mota
• physically assaulted Ms. Alvera, causing Ms. Alvera to go to the hospital. Her mother,
Tamie Alvera, who resided in unit-30 in the complex, at approximately 6:00 am, went to
Ms. Mock in order to get a.key to her daughter's apartment so that she could see whether
Mr. Mota was still in the apartment. At the time, Tamie Alvera told Ms. Mock that Ms.
Alvera had been beaten by Mr. Mota. Ms. Mock wrote up an incident report and sent it
to respondent Corenevsky The investigation revealed that immediately after she was
released from the hospital, Ms. Alvera obtained a restraining order against her husband,
which she showed to Ms. Mock. The'restraining order stated that Mr. Mota could not
contact Ms. Alvera at her residence, place of business, or within 100 feet of Ms. Alvera
and could not contact her by phone or-mail. -The order also stated that Mr, Mota would
move from and not return to their residence.-Ms. Alvera discussed with Ms. Mock
removing Mr. Mota from the Iease. -
The investigation revealed further that Ms. Mock was instructed by Ms. Corencvsky to
terminate Ms. Alvcra's tenancy and issue a 24 hour for cause eviction notice. On August
4, 1999, CBM Group issued a 24 hour notice to Ms. Alvera and Mr. Mota. The notice
stated: "You, someone in your control, or your pet, has seriously threatened immediately
to inflict personal injury, or has inflicted substantial personal injury upon the landlord or
other tenants." The notices specified: "On August 2, 1999 at approximately 6 am.
Humberto Mota reportedly physically attacked Tiffani Alvera in their apartment.
Subsequently, Police were called in."
Page 20 of 25
The investigation established that on August 4, 1999, Ms. Alvcra made an application for
a one bedroom unit at the complex because there was then only one member of the
household. The evidence shows that this application was rejected by the respondents
because of the incident of domestic violence for which Ms. Alvera received the 24 hour
notice. The evidence showed that unit 18, a one bedroom apartment into which Ms.
Alvera eventually moved, was available as of August 4, 1999. On October 8. 199.9. Ms.
Alvera submitted a second application fur aone bedroom apartment. On November 2,
Ms. Alvera signed a lease for a one bedroom apartment, where she resided until she was
later evicted for reasons not directly related to the allegations of this complaint.
The evidence further revealed that on August 6, 1999, Ms. Mock refused to accept Ms.
Alvera's rent for the month of August. The respondents communicated to Ms. Alvera up
through early September, 1999 that they intended to pursue an FED action against her.
On October,26, 1999, an attorney representing the respondents wrote Ms. Alvera
"concerningyour Rental Agreement of[unit 21]." The letter stated:
"As you know, there was a recent incident of violence that took place
between you and another member of your household. It is our
understanding that you have taken steps to ensure that such an incident
will not occur again.
This letter is to advise that Creel:side is very concerned about the effect of
such conduct on other tenants.of the premises. Your conduct and the
conduct of the other tenant would probably have been grounds for
termination of your tenancy. Obviously, Creekside would not desire to
take this action.
This letter is to advise that if there is any type of reoccurrence of the past
events described above, that Creckside would have not other alternative
• but to-cause an eviction to take place. We solicit your cooperation in
continuing to maintain a restraining order or for you to take whatever
action is necessary to make certain that the rules of your tenancy are
followed,"
There is no dispute that the sole reason for the 24 hour notice was respondents' response
to this incident of domestic violence. The evidence shows that none of the other tenants
complained to the respondents that their tenancy had been disrupted or that they had been
injured or feared injury because of the incident. Ms. Mock stated that after Ms. Alvera
vacated the apartment a hole in the wall, which might have been caused by an assault by
Mr. Mots, was discovered, but that she learned of this damage long ager the 24 hour
notice had been issued and that she did not report the hole to her superiors.
The investigation did not establish that Ms. Alvera was treated differently than similarly
situated male tenants. There were no similarly situated male tenants. The evidence also
3
•
Page 21 of 25
revealed that there were at least three incidents of domestic violence at Creekside Village
Apartments, all involving female victims, but respondents knew only about the August,
1999 incident involving Ms. Aivera. -The evidence showed that the respondents issued
three other 24 hour notices. One notice was for criminal activity,one was because the
INS took the entire family away,and one was because a tenant threatened other tenants
with a baseball bat. The evidence also showed that the resident manager filed six incident
reports with upper management during the period June 1, 1999 to January 31, 2000. 'lite
only incident report involving violence, domestic or otherwise, was that involving Ms.
Alvera.
It is the respondents'policy, expressed by respondent Corencvsky,that where there is any
threat or act of violence by a tenant or their guest, the household is terminated. She stated
that the subject property has a "zero tolerance"for violence or threats of violence, and
this policy was affirmed by the ADA/504 Coordinator for CBM Group.. Ms. Corencvsky
stated: "As is often the case in a domestic violence situation the victim does not take
steps to prevent a reoccurrence of violent acts, subjecting other tenants to witness the
scene play out time and time again. 'The reasons we take such a hard stance on the issue
of violence is to maintain a peaceful living environment for all tenants."
Nationally, each year from 1992 to 1996 about 8 in 1,000 women and I in 1,000 men
experienced a violent victimization by an intimate---a current or former spouse,girlfriend
or boyfriend. National statistics also showed that,although less likely than males to -
experience violent crime overall, females are 5 to.8 times more likely than males to be
victimized by an intimate. Other national studies have found that women are as much as
ten times more likely than men to be victimized by an intimate.
National statistics show that 90% to 95% of victims of domestic violence are women.
National estimates are that at least one million women a year:are victims of domestic
violence. A 1998 Oregon Domestic Violence Needs Assessment stated that more than
one in eight (13.3 %) women in the state were the victims of physical abuse by an
intimate in the prior year. Evidence obtained during the investigation showed that 93%
of the victims of domestic violence reported to Clatsop County in 1999 were women.
The 1998 Oregon Domestic Violence Needs Assessment compared the Oregon statistics
to national statistics on the prevalence of domestic violence and found them to be
comparable. National studies using a similar methodology reported that 1 out of every 9
to I out of every 12 women had been victims of physical assault by an intimate partner
within the previous year. This compares to the Oregon study's finding that 1 of every 10
Oregon women have been victims of physical assault.
These statistics demonstrate that the respondents' policy of evicting all members of a
household because of an Incident of domestic violence,regardless of whether the
household member is a victim or a perpetrator of the domestic violence, has an adverse
impact based on sex, because of the disproportionate number of women victims of
domestic violence.
4
Page 22 of 25
The respondents have raised several reasons for their policy. One rationale advanced by
the respondents is the need to protect other tenants both from threats of violence or
violence and from being disturbed in their tenancy. However,.the evidence fails to
support this rationale. In the case of Ms. Alvera, no other tenants complained about the
incident in question and the evidence shows that the only tenant who was aware of the
incident was Ms. Alvera' mother. There were no other records of tenant complaints or
incident reports involving domestic violence though the evidence shows that incidents of
domestic violence were occurring at the complex. Further, there was no evidence in the
investigation to support an assumption that there is a greater probability that persons
living in the immediate vicinity of a household that has incidents of domestic violence
will themselves become victims of that violence.
The respondents also argued that their policy is consistent with and mandated by rules of
Rural Development concerning properties funded by that agency. Rural Development
has implemented regulations and procedures providing that: "Action or conduct of the
tenant or member which disrupts the livability of the project by being a direct threat to
the health or safety of any person, or the right of any tenant or member to the quiet
enjoyment of the premises..." is grounds forterrnination of tenancy. However, Rural
Development's rules and policies also provide: "It is not the intent that this provision-of
material lease violation apply CO innocent members of the tenant's household who am not
engaged in the illegal activity, nor are responsible for control of another household
member or guest." The Rural Development representative responsible for monitoring
Creekside Village Apartments stated that the rule protects innocent.parties.
Respondent Corenevsky also stated that a reason that the respondents evict the entire
household is because a TRO doesn't stop violence, and many men are not afraid of
TROs. The results of national studies on the effectiveness.of restraining orders in
preventing future incidents of domestic violence are mixed. One study showed ithat in the
six months after a restraining order is issued, 65% of the women who obtained the order
reported no further domestic violence problems. Another study showed that future
incidents of violence did occur even after a restraining order was obtained. However, the
respondents' rationale is based on overbroad generalizations that do not take into account
either the individual circumstances of the female victim tenant or all of the actions that
she may have taken to prevent a recurrence of the violence. For example, in the case of
Ms. Alvefa, Mr. Mora was jailed, apparently subsequently left the country, and has had
no further contact with Ms. Alvera.
In issuing a 24 hour notice, the respondents apparently also were relying on an Oregon
State law, ORS 90.400(3),which permits landlords to issue a notice for a tenant to vacate
the property within 24 hours if there is substantial personal injury to the landlord or other
tenants. However, that law,and the legislative history behind it, were not intended to
apply to innocent victims of violence. During the legislative process-witnesses testified
that: "There are special concerns about battered women who might be evicted under this
provision because of the outrageous conduct of an abusive boyfriend;they would be
punished twice; beaten by the boyfriend, then evicted because of the boyfriend's abuse."
5
Page 23 of 25
The evidence taken as a whole establishes that a policy of evicting innocent victims of
domestic violence because of that violence has a disproportionate adverse impact on
women and is not supported by a valid business or health or safety reason by the
respondents.
V. C ONC:LUiL.A\i
For the foregoing reasons, the Department finds reasonable cause to believe that the
complainant has been discriminated against because of her sex in violation of the Fair
Housing Act. A copy of the Final Investigative Report is available by requesting the
Report in writing addressed to the Fair Housing Hub, Northwest/Alaska Area, U.S.
Department of Housing and Urban Development, 909 First Avenue, Suite 205, Seattle,.
Washington 98104.
•
Date udith A. Keeler
'Director, Seattle Fair l lousing Hub
•
6
Page 24 of 25
B. Budget Update
As stated earlier in the meeting: Sylvia Wilson reported the City Council approved the
budget. The budget presented on behalf of the Human Relations Department included
the "Director" title/position be removed and replaced with an "Administrator"
title/position. The approved budget included changing the ADA Coordinator
(Exempt/Salary) position to an ADA Compliance Officer (Non-Exempt/Hourly) position.
There were no other changes to the budget as it was submitted.
8. IDENTIFY ITEMS TO BE PLACED ON NEXT AGENDA
• Update/Approval of CCPD Parking Control Enforcement Actions Resolution
• Disparity Study
• Employment Alliance for People with Disabilities
• ADA Transition Plan
9. ADJOURNMENT
MOTION Motion to adjourn the meeting made by Jacob Sendejar and seconded by Elias Valverde.
- Motion passed. The meeting adjourned at 5:55 p.m.
Page 25 of 25