| • | HUD and DOJ Guidance: | ○ | Joint Statement of The Department of Housing and Urban Development and the Department of Justice, Reasonable Accommodations Under the Fair Housing Act (2004). | | ○ | Joint Statement of The Department of Housing and Urban Development and the Department of Justice, Reasonable Modifications Under the Fair Housing Act (2008). |
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| • | Cases Regarding Elements of RA: | ○ | Giebler v. M&B Associates (9th Cir. 2003) 343 F.3d 1143, 1147 (Elements of RA) | | ○ | Nexus: | ■ | U.S. V. California Mobile Home Park Management Co. 107 F.3d 1374, 1381 (1997 9th Cir.) (stating without a causal link between a housing provider’s policy and a tenant’s injury, there can be no obligation on the part of the housing provider to make a reasonable accommodation) | | ■ | U.S. Airways v. Barnett 535 U.S. 391 (2002 9th Cir.) | | ■ | Dadian v. Village of Wilmette, 269 F.3d 831 (7th Cir. 2001) |
| | ○ | Reasonableness | ■ | U.S. v. California Mobile Home Park Management Co., 29 F.3d 1413, 1417 (9th Cir. 1994) |
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| • | Cases on How and When to Request Reasonable Accommodation | ○ | Prillman v. United Airlines, Inc., (1997) 53 Cal. App. 4th 935 (no need to use the words “reasonable accommodation) | | ○ | Douglas v. Kriegsfeld, 884 A.2d 1109, 1121 (D.C. 2005) (A request for a reasonable accommodation can be made at any time, up to the entry of judgment for possession.) | | ○ | Bhogaita v. Altamonte Heights Condominium Ass’n, Inc., 765 F.3d 1277, 1287 (11th Cir. 2014) (“Housing providers need only the information necessary to apprise them of the disability and the desire and possible need for an accommodation.”) | | | | | ○ | Auburn Woods Owners Association v. Fair Employment and Housing Commission, 121 Cal. App.4th 1578 (Need for interactive process) |
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| • | Cases on Direct Threat | ○ | Roe v. Hous. Auth. Of Boulder, 909 F.Supp. 814 (D. Colo. 1995) (landlord must show that no reasonable accommodation will eliminate or acceptably minimize risk) | | ○ | Boston Housing Authority v. Bridgewaters, 898 N.E.2d 848 (Housing authority failed to make an individualized assessment that tenant posed a direct threat) | | ○ | Sinisgallo v. Town of Islip Housing Authority, 865 F.2d 307 (E.D.N.Y. 2012) (Second chance RA may be reasonable). |
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