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Mason v. Adams County Recorder

901 F.3d 753 (2018)

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Mason v. Adams County Recorder

United States Court of Appeals for the Sixth Circuit
901 F.3d 753 (2018)

  • Written by Haley Gintis, JD

Facts

Darryl Mason (plaintiff), an African American resident of Ohio, filed an action in federal district court under the Fair Housing Act against the Adams County recorder (the county) (defendant). Mason claimed the county had violated the Fair Housing Act by including racially restrictive covenants in land records spanning from 1922 to 1957. Although the county no longer enforced the racially restrictive covenants, Mason argued that permitting the restrictive covenants to remain in the chain of title violated the Fair Housing Act because the act prohibited documents related to the sale or rental of a dwelling that indicated discriminatory behavior based on race. Mason further alleged that he felt unwelcome to buy property with racially restrictive covenants in the chain of title. The county moved to dismiss the case for lack of standing. The district court found that Mason lacked standing because he had not suffered an actual or threatened injury distinct to him, the alleged injury was not caused by the county, and the county had no authority to erase the restrictive covenants from the records. Mason appealed.

Rule of Law

Issue

Holding and Reasoning (Boggs, J.)

Concurrence (Clay, J.)

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