City Wide Associates v. Penfield

Eleanor Penfield (defendant) was a tenant in a federal housing project run by City Wide Associates (landlord) (plaintiff). Penfield was 77 years old and suffered from a mental disability that caused her to hear auditory hallucinations. Penfield’s lease prohibited any defacement or damaging of the property, and the landlord could charge up to two months of rent payments for any tenant-caused damages. Penfield began to hear voices in the apartment walls and threw objects, tossed water, and hit the walls with sticks and brooms. Penfield caused around $500 in damages, which was less than a one-month rental payment. The landlord began an eviction proceeding against Penfield in Massachusetts state housing court. As a defense, Penfield argued that the landlord’s attempted eviction constituted disability discrimination under the Rehabilitation Act. Penfield suggested pausing all eviction steps to allow her to attend a mental-health program. The lower court agreed that Penfield’s suggestion was a reasonable accommodation and that the landlord violated the Rehabilitation Act by not providing the accommodation and by continuing eviction proceedings. The landlord appealed, and the Massachusetts Supreme Judicial Court chose to transfer the case from the appellate court. The court reviewed the lower court’s decision on whether the landlord was obligated to accommodate Penfield’s disability and allow her continued residence despite her violation of the lease’s damage provision.