LEGAL REMEDIES TO FAIR HOUSING COMPLAINTS

Sherry V. Hoffman
shhoffman@state.de.us
Deputy Attorney General for
State Human Relations Commission
 

from a presentation given to the Sussex Housing Group
Georgetown, Delaware, April, 2002

All section references are to the Delaware Fair Housing Act in 6 Del. C. Chapter 46 unless otherwise noted.

I. Plaintiffs
A. Aggrieved person
1. Defined in §4602(2)
  a. "Aggrieved person" includes any person who
  (1) Claims to have been injured, directly or indirectly , by a discriminatory housing practice;
  (2) Believes that such person will be injured, directly or indirectly, by a housing practice that is about to occur; or
  (3) Is associated with a person having a protected status under this chapter and claims to have been injured, directly or indirectly, as a result of a discriminatory housing practice against such person having the protected status.
  (4) Definition of protected status -
  --race
  --color
  --national origin
  --religion
  --creed
  --sex
  --marital status
  --familial status
  --age
  --handicap
  (Delaware not federal)
2. Options - Administrative proceedings or Direct Civil Action.
  a. Complaint filed with the Division of Human Relations (administrative remedy)-§4610
  (1) No fault settlement option
  (2) Fact finding
  (3) Conciliation - confidentiality §4610(d)(1)
  (4) Final Investigative Report available to both parties §4610 (d)(2)
  (5) Choice of Administrative Hearing (Panel) or Civil Action (Court) by either party after charge is issued by the Division §4612
  (6) One year to file
  b. Direct Civil Action - §4613
  (1) no duty to exhaust administrative remedies above
  (2) Attorney General can intervene
  (3) Two years to file excluding any time administrative proceedings pending
   
B. Commission ex rel. Aggrieved person - Election of Civil Action after a charge is issued by Division of Human Relations.
1. Commission is the Plaintiff; aggrieved party is the ‘Relator’
2. Commission is represented by DAG
3. Court of Chancery or Superior Court? - Remedy is overriding factor
4. Aggrieved person has a right to intervene §4612(n)(4)
   
C. State Human Relations Commission-
1. The Commission can file a complaint §4610(a)(1)a.1.
2. A preliminary investigation is authorized under 4610(a)(1)a.3
   
D. Attorney General-
1. Pattern and practice OR General public importance -§4614
2. Zoning §4610(f)(2)c.
3. Enforcement of Conciliation Agreement §4614(b)(2)a.
4. ‘Prompt judicial action’ (preliminary injunction) §4610(e)
See State v. Messick 1998 WL 671279 (Del. Ch.) - not if there is an adequate remedy at law (summary possession)
   
   
II. Remedies based on Forum
   
A. Court of Chancery §4614(d)
1. Injunctive relief
2. Attorney fees, expenses and costs to prevailing party
3. Monetary relief to aggrieved person (actual damages include emotional injury)
   
B. Superior Court
1. Civil Penalty to vindicate the public interest (up to $50,000 first violation and up to $100,000 for subsequent violation)
2. Attorney fees, expenses and costs to prevailing party
3. Monetary relief to aggrieved person (actual damages include emotional injury)
4. Punitive damages §4612(n)(5) and §4613
   
C. Justice of the Peace Court
1. 25 Del. C. §5116 and §5313 - Landlord Tenant
  a. Expenses for substitute housing
  b. Possession
  c. Treble damages for unlawful ouster or 3 times rent during period of exclusion
  d. Costs NOT attorney fees
2. Unlike Title 6, the Landlord Tenant Code prohibits discrimination based on occupation
   
D. State Human Relations Commission - administrative remedy (Analogous to HUD ex rel. Aggrieved person before Administrative Law Judge under the federal Fair Housing Statute 42 U.S.C.§ 3612) §4612(g)(3)
  1. Actual damages
  2. Cost, expenses, attorney fees
  3. Injunctive relief
  4. A civil penalty to vindicate the public interest
  a. up to $10,000 first time
  b. up to $25,000 next time within five years of charge
  c. up to $50,000 if two or more time within seven years of charge
  d. time periods don’t count if it is the same natural person
   
E. Federal District Court - Complaints under the federal Fair Housing Act 42 U.S.C. Chapter 36
  1. Filed by aggrieved person or U.S. Attorney - not State agency
  2. Injunctive relief
  3. Actual and punitive damages
  4. Attorney’s fees and costs to prevailing party
  5. In an action brought by the U.S. Attorney - civil penalties to vindicate the public interest (up to $50,000 first time and up to $100,000 subsequent violation)
   
   
III. Theories
A. Disparate treatment
B. Disparate impact - statistical evidence
C. Proof - direct or circumstantial

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