Court: District Court, District of Columbia; January 2, 2001; Federal District Court
Capital City Mortgage Corporation and Thomas K. Nash sought partial summary judgment against plaintiffs Clyde Hargraves and Erlinda Cooper, claiming they failed to state viable causes of action under the Fair Housing Act, the Equal Credit Opportunity Act (ECOA), and Sections 1981 and 1982. The court, having received more detailed briefing, granted the motion for reconsideration concerning the Section 1981 and ECOA claims but denied it for the Fair Housing Act and Section 1982 claims.
The court emphasized the necessity of demonstrating an 'injury in fact' for standing under Article III. Although Hargraves and Cooper alleged personal injuries, including humiliation and financial loss through their contributions to the church's loan repayment, they lacked standing for the ECOA and Section 1981 claims as they did not individually apply for or receive credit. The ECOA allows causes of action solely for the church, and Section 1981 protects contractual rights, which were held by the church and not the individual plaintiffs. Consequently, the plaintiffs could not assert the church's legal interests.
Humiliation experienced by the President and principal shareholder due to discrimination related to the corporation does not establish a cause of action under Section 1981. Section 1982 ensures the right 'to inherit, purchase, lease, sell, hold, and convey real and personal property' and has been interpreted to include the 'use' of property. Relevant case law, including United States v. Brown and United States v. Greer, supports the notion that such rights extend to the use of property, including for members of a synagogue. Additionally, being a guest at a swimming pool has been recognized as a property right that individuals can 'hold' under Section 1982, as established in Olzman v. Lake Hills Swim Club, Inc.
Mr. Hargraves and Ms. Cooper, as the church's pastor and a board member, respectively, have a legitimate claim to 'hold' church property under this interpretation, thus possessing standing to pursue claims under Section 1982. In contrast, claims under the Fair Housing Act are analyzed differently, as it grants standing to all 'aggrieved persons' as per 42 U.S.C. 3613, which includes individuals alleging injury from discriminatory housing practices. Consequently, despite the discrimination being directed at the church, Mr. Hargraves and Ms. Cooper have standing to sue under the Fair Housing Act.
The court partially granted Capital City's motion for reconsideration, resulting in summary judgment against Mr. Hargraves and Ms. Cooper regarding their Section 1981 and ECOA claims. However, the motion was denied concerning their claims under Section 1982 and the Fair Housing Act. The order acknowledges that Capital City's motion will be treated as made under Federal Rule of Civil Procedure 60(b), despite a lack of explicit authority citation.
