Marks v. BLDG Management Co.
Docket: No. 02-7637
Court: Court of Appeals for the Second Circuit; March 17, 2003; Federal Appellate Court
The United States Court of Appeals for the Second Circuit affirmed the District Court's judgment regarding a case involving a plaintiff who lived in a rent-controlled apartment in New York City for 38 years. The plaintiff alleged violations under the Fair Housing Act (FHA) and related New York laws, claiming that her request in 1997 to leave a roommate in her apartment while she traveled to Florida for the winter was unjustly denied as a failure to make a reasonable accommodation for her health condition. Additionally, she asserted that this denial, along with termination proceedings initiated in 1999, constituted unlawful retaliation for a previous lawsuit she had filed in 1996. At trial, a jury found in favor of the plaintiff on both claims, awarding her $50,000 in compensatory damages and $250,000 in punitive damages. However, following the trial, Magistrate Judge Katz granted the defendants' motion for judgment as a matter of law, reasoning that the plaintiff sought an "economic" accommodation not recognized by the FHA and that the retaliatory denial did not cause her any harm. The plaintiff appealed this judgment, seeking to reinstate the jury's verdict. The appellate court, after reviewing the arguments presented, upheld the District Court's decision based on the reasoning articulated in Magistrate Judge Katz's Memorandum Opinion and Order dated April 26, 2002. The court concluded that the District Court's grant of judgment in favor of the defendants was warranted.