Tenant Must Restate Discrimination Claims After Eviction

Tenant sued the YWCA, which received federal funding to provide supportive housing to tenant in landlord's building. After tenant was evicted, tenant claimed housing discrimination by the YWCA under the Fair Housing Act and Violence Against Women Act. Tenant's spouse had made a death threat, and tenant claimed that the YWCA required her to accept harassment and discrimination as a condition of tenancy. The court ruled against tenant. Since tenant had been evicted, she couldn't get preventive, injunctive relief under the federal Anti-Injunction Act, the Rooker-Feldman doctrine, or the Younger abstention. Since the YWCA sublet the apartment to tenant in landlord's building, it could be subject to a tenant claim under the FHA if tenant proved discriminatory activity. But tenant would have to restate those claims separately.

Doe v. YWCA of Northeastern NY: 2019-cv-456, NYLJ No. 1581614802 (NDNY; 2/12/20; McAvoy, J)