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Paraquad, Inc., a Missouri Non-Profit Corporation Mental Health Association, of St. Louis, a Missouri Non-Profit Corporation Depressive and Manic Depressive Association, of St. Louis, a Missouri Non-Profit Corporation Beatrice E. Creason Ariel Marquardt v. St. Louis Housing Authority, a Missouri Municipal Corporation Cheryl A. Lovell, in His Official Capacity as Executive Director of the St. Louis Housing Authority

Citations: 259 F.3d 956; 2001 U.S. App. LEXIS 17688Docket: 00-1948

Court: Court of Appeals for the Eighth Circuit; August 8, 2001; Federal Appellate Court

Narrative Opinion Summary

The case involves an appeal by plaintiffs, including disabled tenants and non-profit organizations, against the St. Louis Housing Authority (SLHA) concerning the HOPE VI revitalization project for the Darst-Webbe public housing complex. The plaintiffs claimed that SLHA's actions violated the Fair Housing Act, the Rehabilitation Act, the Americans with Disabilities Act, and the Equal Protection Clause by failing to provide adequate replacement housing and supportive services for disabled families. The district court granted summary judgment to SLHA, citing lack of standing, lack of ripeness, and mootness of claims. Upon appeal, the Eighth Circuit Court affirmed the district court's decision, emphasizing that the plaintiffs' claims were not ripe for adjudication as they could not demonstrate an imminent threat of injury from the HOPE VI plan. The court found no evidence of disabled individuals being denied accessible housing. While the plaintiffs referenced past cases with similar issues, the court distinguished these cases based on the absence of resolved uncertainties in the current case. Judge Arnold dissented, arguing that the exclusion of younger disabled tenants from certain units reserved for older tenants constitutes a ripe claim, akin to racial discrimination cases. Despite this dissent, the appellate court upheld the lower court's ruling, denying the plaintiffs' appeal.

Legal Issues Addressed

Equal Treatment under the Fair Housing Act and ADA

Application: Plaintiffs argued that the exclusion of nonelderly disabled individuals from an elderly-only facility under the HOPE VI plan constituted unequal treatment.

Reasoning: The plaintiffs argued on appeal that their lawsuit centers on the unequal housing and service opportunities for disabled individuals under the HOPE VI plan, asserting that the exclusion of nonelderly disabled individuals from an elderly-only facility constitutes a prior injury.

Mootness in Legal Claims

Application: Some of the plaintiffs' claims were deemed moot, contributing to the summary judgment in favor of SLHA.

Reasoning: The district court previously granted summary judgment to SLHA, ruling that...some claims were moot.

Ripeness Doctrine in Judicial Review

Application: The Eighth Circuit Court affirmed that the plaintiffs' claims were not ripe for adjudication as they failed to demonstrate an imminent threat of injury.

Reasoning: The district court determined that the plaintiffs' claims regarding the HOPE VI project were not ripe, as they failed to demonstrate any imminent threat of injury.

Standing in Federal Court

Application: The district court ruled that the plaintiffs lacked standing to pursue their claims, a decision upheld by the Eighth Circuit Court.

Reasoning: The district court previously granted summary judgment to SLHA, ruling that the plaintiffs lacked standing, the claims were not ripe for adjudication, and some claims were moot.