Congdon v. Strine
United States District Court for the Eastern District of Pennsylvania
854 F. Supp. 355 (1994)
- Written by Alexander Hager-DeMyer, JD
Facts
Linda Congdon (plaintiff) was a month-to-month tenant in a fourth-floor apartment of a building owned by Walter Strine (defendant). Congdon used a wheelchair for mobility and required elevator access to enter and exit her apartment. Strine maintained a repair contract for the building’s elevator, but the elevator began experiencing recurring breakdowns. During these breakdowns, Congdon was unable to enter or leave her apartment and missed appointments and other activities. Congdon filed complaints with state and federal housing authorities. Strine notified Congdon that he would not renew Congdon’s apartment lease and that she had to vacate the premises. Strine offered to rent Congdon a ground-floor apartment or an apartment in another building, but Congdon rejected both offers as unsuitable. Congdon filed suit in federal district court, alleging violations of the Fair Housing Amendments Act (FHAA). Congdon claimed that Strine denied her housing based on her disability and discriminated against her by providing poor elevator service. The district court found that Congdon was not denied housing under the FHAA because Strine offered Congdon alternate apartment options and Congdon was merely inconvenienced by the elevator’s difficulties rather than truly denied her living quarters. The court then addressed Congdon’s discrimination claims.
Rule of Law
Issue
Holding and Reasoning (Dalzell, J.)
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