Keck v. Graham Hotel Systems, Inc.

Alfreda Keck and Devon Keck (plaintiffs), a Black couple, repeatedly attempted to enter into a contract to hold their wedding reception at the Crowne Plaza Hotel in Anne Arbor, Michigan, but the hotel declined to respond to their numerous visits, phone calls, and offers to pay the required deposit. After three months of fruitless attempts, the Kecks decided to hold their reception elsewhere. After making this decision, the couple filed a complaint with the Fair Housing Center of Southeastern Michigan (the center). The center conducted four separate tests to determine whether the hotel was engaging in discriminatory treatment of wedding clients. Three of the four tests indicated discriminatory treatment. The Kecks then sued the hotel, alleging that it had discriminated against them because of their race in violation of 42 U.S.C. § 1981. During discovery, the Kecks requested records of all the hotel’s wedding contracts during the period in which the Kecks had attempted to procure the hotel’s services. The hotel refused to provide the records. It attributed its lack of responsiveness to the fact that it had changed names, becoming the Kensington Court Hotel and undergoing an allegedly tumultuous transition. Despite the name change, the hotel’s management and lower-level staff remained the same. The district court granted the hotel’s motion for summary judgment, and the Kecks appealed.