Bhogaita v. Altamonte Heights Condominium Association

765 F.3d 1277 (2014)

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Bhogaita v. Altamonte Heights Condominium Association

United States Court of Appeals for the Eleventh Circuit
765 F.3d 1277 (2014)

DD

Facts

Ajit Bhogaita (plaintiff) suffered from post-traumatic stress disorder (PTSD). Bhogaita owned a condominium unit in a complex that was managed by the Altamonte Heights Condominium Association, Inc. (association) (defendant). The association had a rule prohibiting owners from keeping dogs weighing more than 25 pounds. Bhogaita acquired a dog that exceeded the weight limit. The dog served as an emotional-support animal. The association demanded that Bhogaita remove the dog from his unit. Bhogaita submitted an accommodation request to the association, asking the association to allow him to keep the dog in his unit. In support of his request, Bhogaita submitted letters from his psychiatrist, Dr. Shih-Tzung Li. Dr. Li’s letters stated that Bhogaita’s PTSD substantially limited Bhogaita’s ability to work and explained that the dog alleviated the effects of Bhogaita’s PTSD. The association did not make a final decision on Bhogaita’s requested accommodation. Subsequently, Bhogaita brought suit, contending that the association violated the Fair Housing Act (FHA). The district court held in favor of Bhogaita. The association appealed.

Rule of Law

Issue

Holding and Reasoning (Dubina, J.)

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