United States v. Rupp

In 2016, Louis Rupp (defendant), a longtime landlord in St. Louis, Missouri, rented an apartment to Laura Erwin and Mack Teal, an unmarried couple who planned to live in the apartment with their six-year-old son. Although Rupp’s rental applications stated that no children were allowed, he permitted the family to move in on a “trial basis” and added a handwritten note in the lease to that effect. In May 2017, the family renewed the lease. Shortly after, Erwin gave birth to a second child via emergency C-section. Two weeks after the birth, while Erwin was still recovering, Rupp issued an eviction notice to the family for violating the lease’s “no children” clause. The notice demanded they vacate by July 31, 2017, and threatened legal action if they did not comply. Despite the family’s pleas for more time, Rupp insisted they leave. The eviction caused the family severe emotional and physical stress, as they were forced to relocate on short notice while caring for a newborn and dealing with Erwin’s postsurgical recovery. The government (plaintiff) brought suit against Rupp under the Fair Housing Act (FHA) on behalf of the Erwin-Teal family. The district court granted summary judgment in favor of the government, finding that Rupp had violated the FHA. The case then proceeded to a jury trial on the issue of damages. The jury awarded the family $14,400 in compensatory damages and $60,000 in punitive damages. Rupp moved to set aside or reduce the punitive damages, arguing, in the alternative, that there was insufficient basis to submit punitive damages to the jury and that the amount was unconstitutionally excessive. The district court denied the motion. Rupp appealed.