One Love Housing, LLC v. City of Anoka, MN, No. 22-3071 (8th Cir. 2024)
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In the case before the United States Court of Appeals for the Eighth Circuit, One Love Housing, LLC, a company that operates a residential sober living home in Anoka, Minnesota, sued the City of Anoka for refusing to grant a waiver from the city's zoning regulations. The regulations permit only a single family or a group of not more than four unrelated persons to reside together in the area where the sober home is located. One Love wanted to accommodate seven unrelated recovering addicts in the home. One Love and two residents of the home alleged that the city violated the Americans with Disabilities Act and the Fair Housing Act by refusing to grant this waiver.
The district court granted One Love summary judgment on its claim that the city failed to reasonably accommodate the sober home's request. The court ordered the city to grant the waiver for One Love to house seven unrelated individuals recovering from substance abuse. The city appealed this decision.
The United States Court of Appeals for the Eighth Circuit reversed the district court's decision and remanded the case for further proceedings. The appellate court held that the district court erred by considering evidence that was not presented to the city council when it denied One Love's request for a waiver. The appellate court also found that the district court erred in granting summary judgment to One Love because there was a genuine dispute over whether the requested accommodation was reasonable and necessary. The court stated that the financial viability of One Love's sober home is relevant only if One Love can prove that the service it offers provides a therapeutic benefit that is necessary for people recovering from alcohol or drug abuse to successfully live in a residential neighborhood without relapsing. The court concluded that there are genuine issues of disputed fact on these issues. The court also declined to rule on One Love's disparate treatment and disparate impact claims, leaving those for the district court to address on remand.
Court Description: [Loken, Author, with Smith, Chief Judge, and Colloton, Circuit Judge] Civil case - Americans with Disabilities Act. Plaintiffs operate sober living homes for recovering alcoholics and substance abusers and sought to operate a home in an area the City of Anoka has zoned for single families or groups of not more than four unrelated persons; plaintiffs asked the City to grant an accommodation to permit them to house up to seven unrelated persons in the home, and the City Council denied the request. Plaintiffs then brought this suit alleging disparate treatment and impact and failure-to-accommodate claims under both the ADA and the Fair Housing Act. The district court granted plaintiffs summary judgment on their failure-to-accommodate claims and ordered the City to grant plaintiffs' request for a reasonable accommodation. The City appeals. Held: there are genuine issues of material fact on plaintiffs' reasonable accommodation claim, and the district court erred in granting plaintiffs summary judgment on the claim. The district court erred in considering a report on the accommodation which had not been presented to the City Council; on the record before the City Council a reasonable factfinder could find that plaintiff's self-serving, conclusory evidence failed to prove that seven residents are necessary for its sober home to provide a therapeutic environment; there were also genuine issues concerning the issue of financial viability as part of the reasonable accommodation issue; on remand, the district court can also take up plaintiffs' disparate impact and treatment claims.
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