thank you your honors may please the fort i represent mr lawrence falls very who was and still is a resident of a mobile home park in santa monica in two teenager i understand that's a disputed fact but nevertheless it was a fact that my client supported it was sworn testimony in two thousand and fifteen or requested of the city of santa when his parents got divorced and his father lived in this mobile home park and his mother lives also in the city of santa monica not far away so he lived there as a cop with his family since  dollars and in santa monica where you have a rent control jurisdiction it really doesn't matter if a lease is renewed it because of the way the law operates month lease expires it may be sixty five years old but that will still be the least that is in effect because of the way rent control works so no we've never argued that there is a discrimination in terms of failing to give him a lease it is unnecessary her because under f two a burglar would not be a person residing in the rented dwelling and he would not be a person associated with the person in the rented santa monica's view of mr lawrence all varies status was it's undisputed that he was a person residing in the dwelling with his father and he thought he was a person associated with his father but let's talk about fathers because i've given this a lot of thought if mr solsbury just climbed in the window of a mobile home park and that was their position you would expect that the city of santa monica would call the police and say there is a squatter in this mobile home please get him out and then if the police came and declined to arrest the slaughter the city of santa monica court that has jurisdiction to decide the question of whether or not someone is unlawfully holding over a tenancy that's where that has to be decided if we were to conclude that it was an element of the vegetable he had to have some right to the occupancy of the premises under state law is it your had a right to be in the property under state law no the court did make that it did say that but even if this case were tried to a court and a unanimous jury in federal court decided that he had no right to the premises after going home from the trial losing mr solidary would then still be an authorised occupant of the mobile home park because a federal court has absolutely no jurisdiction thousand and seven case out of the southern district of california and there was a very interesting case your honor because the landlord took the position that because of the fact that this is involved housing authority that presided over indian reservation that it would have no way to leave it the defendants but for in federal court and that court found that it had no jurisdiction and it searched for it and  even recognized the plaintiffs says there without a remedy if i don't grant an order of eviction and have the of marshals come in and get the defendants but you know respectfully to the housing if found there is no federal common law right of diction it just doesn't exist furthermore if i move to city law the fact that mr solsbury had lived with his father for a year and no one disputed that means that he could not have been even it did under city law but he but the proper forum to decide that is definitely  not federal court they has no jurisdiction to decide that question at all but there's a more fund a believe it or not there's an even more fundamental reason why the district court can't make that decision your honor because there's not a moment of the claim the elements of the claim are that the plaintiff is handicapped that defendant knew of the handicapped the accommodation may be necessary the accommodation is reasonable and that the defendant refused to make that accommodation that's where the inquiry ends now you can look at the fair housing amendments act and see that mr lawrence old barry was definitely a person associated with that person a renter under everyone's facts that we agreed upon and that the landlord refused to make any accommodations reasonable necessary or unnecessary i'd certainly like to reserve some time to talk about the interactive process if it's important for your honour's to hear that the district court's ruling in this case was limited and it was appropriate given the unique that x of the case and the granting of the function for summary judgment on the sole cause of action for violations of their housing at should be  the city as decision not to grant the specific parking accommodation at issue here was basically was based simply on the fact that parking spaces in this affordable housing park are all for authorized residents tenants or their sentially decided a state real property possession issue well your honor i don't have a case directly on point but i do want to point to the williams case out of new york and that is actually a little bit different  tendency does not have to be expressed as ms campbell has pointed out it can also be implied but nothing in terms of cities actions here and especially with the timing of accommodations for funds that were made in th potentially displace individuals do you qualify and are willing to demonstrate a willingness to comply with the rules and regulations of unaffordability or to the housing part point was pacifically noted regard to the williams case which did involve someone who they said was not authorized to reside in that case mr williams have moved into his mother's house in the housing authority and sought to be included in that household and that was a that was adjudicated administratively and on appeal from the administrative decision then later they even did mr williams and mr williams stipulated to being a victim in state court and then after he was even did he sued for sorry violation of the f a a saying that his just they should give him this apartment is an accommodation of his disability and the victory court said this well we can't do that because to do that the housing authority would have to violate federal law in order to comply with federal law so we're going to find that you don't make it on the reasonable ness element of the claim you see  this because mr williams is right to reside in there was adjudicated in state court and administratively prior to his lawsuit your honor it's important to note that even a tenet i need to park close to the front door for these next two weeks at least because i have a broken leg and the landlord if he can do it has to grant that accommodation while the dispute regarding his candidacy is being adjudicated in the proper forum which is state court here the city of santa monica took no steps to evict mr zones very notwithstanding miscue guards reference to  he was a squatter so the when we use the word squatter unfortunately we imply a foregone conclusion but if the squatter is not removed by law enforcement and is asserting a right to tenancy that has to be determined in the state court them they have a right not to rent to people who don't qualify but they don't have the right to contract between the city of santa monica and a rd party changes the fact that the people who were there before they entered into that agreement still have the right of tendency the regulatory  itself exempted mr saul barry from having two income qualify notwithstanding the fact that he probably could