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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No.: 1:20-CV-22665-DPG

FLORIDA FAIR HOUSING ALLIANCE, INC.,

Plaintiff,

v.

THE PALM GRAND, LLC,

Defendant.

_______________________________________/

FIRST AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL

Plaintiff Florida Fair Housing Alliance, Inc. (the “FFH Alliance” or “Plaintiff”) sues 

Defendant The Palm Grand, LLC (“Defendant”), under a theory of disparate-impact liability,

for violating 42 U.S.C. § 3601 et seq., the Fair Housing Act.

INTRODUCTION

1. Despite making up less than one-third (29%) of the total U.S. population, Black 

and Hispanic individuals represent more than half (58%) of the individuals convicted of any

felony. In light of this dystopian reality, the screening practices Defendant directs at individuals it 

(Defendant) suspects to have been convicted of any felony has a disparate impact on Black and 

Hispanic individuals. 

2. As confirmed by FFH Alliance’s investigation of Defendant on May 06, 2020, 

Defendant has erected arbitrary, unnecessary, and otherwise hidden, barriers to housing that have 

an unjustifiable disparate impact on Black and Hispanic individuals. In short, the screening 

practices Defendant directs at individuals it (Defendant) so much as suspects as have any felony

conviction has a disparate impact on Black and Hispanics individuals because, despite making up 

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less than one-third of the population, Black and Hispanic represent more than half of all those 

convicted of any felony.

3. Yet, make no mistake, Plaintiff is not attempting to hold Defendant accountable for 

the disproportionate criminal prosecution unjustly endured by Black and Hispanic 

individuals. Rather, in acknowledgment of such undeniable fact, Plaintiff brings this action to 

eliminate the below-evidenced screening practice of Defendant because, although facially neutral, 

such practice is an unnecessary, arbitrary, and artificial barrier to housing that disproportionately 

impacts Black and Hispanic individuals. 

JURISDICTION AND VENUE

4. Jurisdiction of this Court arises under 42 U.S.C. § 3613(a), 28 U.S.C. § 1331, and 

28 U.S.C. § 1337.

5. Venue in this District is proper because, Plaintiff resides in this District, Defendant 

transacts business in this District, and the complained conduct of Defendant occurred in this 

District.

PARTIES

6. The FFH Alliance is a fair housing advocacy organization and non-profit 

corporation formed in Florida, and headquartered in Miami-Dade, Florida. The FFH Alliance 

offers a variety of programs and services designed to advance fair housing in Florida. To advance 

its mission of ensuring equal access to housing for all, the FFH Alliance engages in education and 

outreach; provides counseling to individuals facing discrimination; works with local and federal 

officials to enhance fair housing laws and their enforcement; undertakes investigations to 

uncover unlawful discrimination; and, when necessary, initiates enforcement actions.

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7. In the eyes of Plaintiff, to combat the perpetuation of segregation and stem the 

discriminatory impact of needlessly unjust practices, housing providers large and small must 

evaluate and revise the role that criminal records screening policies and practices play in their 

application decisions to ensure that they are serving a substantial, legitimate, non-discriminatory 

interest and are not a proxy for racial discrimination

8. Defendant is a Florida limited liability company, with its principal place of business 

located in Boca Raton, Florida.

DEMAND FOR JURY TRIAL

9. Plaintiff, respectfully, demands a trial by jury on all counts and issues so triable.

ALLEGATIONS

10. Approximately 1.5 million individuals are currently serving a sentence of more than 

one year, i.e., the repayment phrase of a felony-level debt to society, under the jurisdiction of state 

or federal correctional authorities in the United States. With respect to these individuals’ 

demographics, according to the Bureau of Justice Statistics: 30% are White, 33% are Black, and 

25% are Hispanic.1In comparison to the demographics of the United States population (the total 

of which is estimated at 308 million), however, according to the U.S. Census Bureau: 63% of the 

population is White, 13% of the population is Black, 16% of the population is Hispanic.2

11. Despite making up a fractional percentage of the United States population in 

comparison to Whites, Hispanic individuals, for example, are three times more likely to be 

1 Bureau of Justice Statistics, U.S. Dep’t of Justice, Prisoners in 2017, 15 (April 2019), available 

at https://www.bjs.gov/content/pub/pdf/p17.pdf.

2 U.S. Census Bureau, U.S. Dep’t of Commerce, Overview of Race and Hispanic Origin: 2010, 6

(March 2011), available at https://www.census.gov/prod/cen2010/briefs/c2010br-02.pdf.

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convicted and incarcerated than that of White individuals.3 Thus, in simplest terms, a policy, 

procedure, or practice that arbitrarily denies, without any consideration, housing to individuals 

with a felony conviction will absolutely have a disparate impact on Black and Hispanic individuals. 

12. Pursuant to its mission of ensuring equal access to housing for all, the FFH Alliance 

began investigating the “Palm Bay Grand” apartment community, located at 145 Cinnamon Cove 

Drive, Melbourne, Florida 32901 (the “Complex”), for discriminatory housing practices.

13. Defendant is the owner and otherwise landlord of the Complex.

14. On May 06, 2020, the FFH Alliance tested the Complex for unlawful 

discriminatory housing practices using a field tester. 

15. The field tester used by the FFH Alliance to test the Complex (“Field Tester” or 

“FT”) is a sui juris Hispanic male with a felony conviction.

16. On May 06, 2020, at approximately 12:16 p.m., FT called the Complex at phone 

number 321-210-1009. After dialing this number FT was connected to an agent of Defendant, of 

whom identified herself as “Julia.” FT first asked whether rental property was available, to which 

Defendant responded, without hesitation, a one-bedroom apartment was available (the 

“Dwelling”). FT then asked whether his (FT’s) rental application would be denied due to FT’s 

record felony conviction, to which Defendant retorted: “yes you would.”

17. Defendant’s response to FT regarding convicted-felon applicants demonstrates that 

Defendant directs individuals convicted of a felony, the majority of which are disproportionately 

Black and Hispanic, away from both the Dwelling and the Complex.

18. Defendant did not perform any investigation or inquiry into the felony conviction 

had by FT. For example, Defendant did not inquire into the type of felony, the date of conviction, 

3

Supra at FN. 5.

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the nature of the conviction, let alone the circumstances surrounding the felony conviction had by 

FT. Defendant simply identified FT as an individual with a felony conviction, and without any 

inquiry or investigation, chose to deter FT from renting the property Defendant held open to the 

public due to FT’s record felony conviction.

19. The statements made by Defendant to FT regarding applicants previously convicted 

of a felony further serves to discourage Black and Hispanic individuals with a criminal record from 

applying, inspecting, and renting the Dwelling, and otherwise restricts the choices of these 

individuals in connection with attempts to seek, negotiate for, and ultimately rent the Dwelling.

20. Consistent with the FFH Alliance’s suspicion, that is, until such suspicion was 

confirmed on May 06, 2020, Defendant, whether intentionally or ignorantly, perpetuates 

segregated housing patterns and discourages and/or obstructs choices in the applicable community, 

neighborhood, and/or development. 

21. Simply put, Defendant’s decision to steer individuals convicted of any felony away 

from the Complex and/or Dwelling, i.e., to flat out tell FT that individuals convicted of a felony 

are not accepted, all without conducting even the most minimal inquiry into such an individual’s 

circumstances, has a disparate impact on Black and Hispanic individuals.

22. The harm inflicted by discriminatory practices and/or policies directed at 

individuals with criminal records, like those of Defendant, is significant, not only in terms of the 

sheer number of people affected, but also in terms of the consequences for the wellbeing of our 

communities. In fact, securing safe and affordable housing is a particularly crucial need for 

individuals reentering their communities immediately after time in prison.

23. Research shows that success in finding adequate housing is critically important to 

allowing reentrants to secure employment, government benefits, and other community ties. 

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Housing has been characterized, properly, as the “lynchpin that holds the reintegration process 

together.”4

24. As another expert put it, “[t]he search for permanent, sustainable housing portends 

success or failure for the entire reintegration process.”5

25. On April 4, 2016, more than four years ago, the U.S. Department of Housing and 

Urban Development (“HUD”) issued a document titled “Office of General Counsel Guidance on 

Application of Fair Housing Act Standards to the Use of Criminal Records by Providers of 

Housing and Real Estate-Related Transactions” (the “HUD Guidance”).

26. The HUD Guidance noted that “criminal history-based restrictions on access to 

housing are likely disproportionately to burden African Americans and Hispanics.” Id. HUD found 

that “where a policy or practice that restricts access to housing on the basis of criminal background 

has a disparate impact on individuals of a particular race ... such policy or practice is unlawful 

under the Fair Housing Act if it is not necessary to serve a substantial, legitimate, 

nondiscriminatory interest of the housing provider.” See HUD Guidance. 

27. Ultimately, HUD concluded that “a discriminatory effect resulting from a policy 

or practice that denies housing to anyone with a prior arrest or any kind of criminal 

conviction cannot be justified, and therefore such a practice would violate the Fair Housing 

Act.” Id. (emphasis added). 

28. Further, HUD made clear that no substantial, legitimate, nondiscriminatory interest 

can be served where “[a] housing provider ... imposes a blanket prohibition on any person with 

4

Jeremy Travis, But They All Come Back: Facing Challenges of Prisoner Reentry 219 (2005).

5 Barbara H. Zaitzow, We’ve Come a Long Way, Baby...Or Have We? Challenges and 

Opportunities for Incarcerated Women to Overcome Reentry Barriers 233 (in Global Perspectives 

on Re-Entry (2011)).

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any conviction record – no matter when the conviction occurred, what the underlying conduct 

entailed, or what the convicted person has done since then.” Id. The FFH Alliance finds the same. 

29. According to recent data, studies, and HUD findings, Hispanic and Black people 

are arrested, convicted, and imprisoned at vastly disproportionate in country as a whole, of which 

is consistent within the State of Florida. As such, the discriminatory steering practices of 

Defendant, those the above-transcribed interaction between Defendant and FT exemplifies, 

actually and predictably results in a disparate impact to Hispanic and Black people. 

30. Defendant’s practice or otherwise policy regarding the criminal history of 

individuals seeking to rent, utilize, or otherwise occupy the Dwelling is unlawful under the Fair 

Housing Act, as it has a disparate impact on Black and Hispanic individuals and otherwise fails to 

serve a substantial, legitimate, nondiscriminatory interest of the housing provider.

31. Defendant’s acts impaired the FFH Alliance’s ability to engage in projects by 

forcing the FFH Alliance to devote resources to counteract the herein complained of actions of 

Defendant. Further, the resources diverted are independent of the cost of detecting and challenging,

via non-legal means, the alleged misconduct of Defendant. Simply put, the FFH Alliance was 

forced to divert resources from, among other things, its counseling, outreach, and educational

efforts, and into the advancement of this litigation to protect the FFH Alliance’s core mission. 

32. Despite the prelitigation efforts of the FFH Alliance, Defendant refuses to evaluate 

and revise the role that criminal records, or more pointedly, the mere suspicion of a felony 

conviction, play in Defendant’s screening policies and practices to ensure that Defendant is not 

perpetuating segregation and otherwise needlessly erecting barriers to housing. 

33. Consistent with FFH Alliance’s fair housing testing efforts, FFH Alliance has a 

practice of continuing to monitor and test those entities and individuals found to have been engaged 

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in discriminatory housing practices. FFH Alliance’s will continue monitoring Defendant, and its 

agents, in order to determine its (Defendant’s) ongoing compliance with the Fair Housing Act.

DISPARATE IMPACT LIABILITY6

34. Inclusive Communities represents the Supreme Court’s codification of disparate 

impact liability under the FHA. 135 S. Ct. 2507 at 2525 (“The Court holds that disparate-impact 

claims are cognizable under the Fair Housing Act upon considering its results-oriented language, 

the Court’s interpretation of similar language in Title VII and the ADEA, Congress’ ratification of 

disparate-impact claims in 1988 against the backdrop of the unanimous view of nine Courts of 

Appeals, and the statutory purpose.”). With respect to the facts at play in Inclusive Communities, 

however, the Supreme Court was keen to exemplify that such were not that of a “heartland” 

disparate impact case. Inclusive Communities at 2525 (wherein the Supreme Court made clear, 

“[u]nlike the heartland of disparate-impact suits targeting artificial barriers to housing, the 

underlying dispute in this case involves a novel theory of liability.”). 

35. Despite the ill-suited factual circumstances of Inclusive Communities, the Supreme 

Court made clear that “[a] plaintiff who fails to allege facts at the pleading stage or produce 

statistical evidence demonstrating a causal connection cannot make out a prima facie case of 

disparate impact.” Inclusive Communities, 135 S. Ct. 2507 at 2524 (emphasis added). Id. at 2524 

(exemplifying that a plaintiff must demonstrate, whether via allegations or statistical evidence, a 

“causal connection” between the specific adverse racial or ethnic disparity and the challenged 

policy). In the vein of meeting the “robust causality” pleading requirement, though, the Supreme 

Court noted the limitations of statistical evidence. Inclusive Communities at 2522 (“[b]ut 

6 The following is proffered in light of Defendant’s Motion to Dismiss [D.E. 6], or more pointedly, 

the argument therein with respect to the sufficiency of Plaintiff’s claim, so that the precious

resources of both Plaintiff and this Court are preserved for meritorious challenges.

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disparate-impact liability has always been properly limited in key respects that avoid the serious 

constitutional questions that might arise under the FHA, for instance, if such liability were 

imposed based solely on a showing of a statistical disparity.” (emphasis added)), 

36. In simple terms, under Inclusive Communities, statistical evidence is simply one of 

the tools used to establish the robust causality component of the overarching prima facie case –

but make no mistake – Plaintiff is not claiming statistical information is unhelpful or useless in 

the context of a disparate impact claim.

7 Rather, Plaintiff wants to make clear: Inclusive 

Communities does not make the provision of statistical evidence a necessary component of a prima 

facie case of disparate impact. See, e.g., Corelogic Rental Prop. Sols., LLC, 369 F. Supp. 3d 362 

at 379 (rejecting the defendant’s argument that the plaintiffs’ “disparate impact claim fails because 

it is not supported by statistical evidence,” and doing so, recognizing that, although statistical 

evidence “is not required,” the plaintiffs had offered “statistical support for their claims.” 

(emphasis added)).

37. In the context of the “robust causality requirement” set by Inclusive Communities, 

in Oviedo Town Ctr. II, L.L.L.P. v. Ciy of Oviedo, the Eleventh Circuit observed that, “[a]lthough 

[the Supreme Court] left space for the lower courts to elaborate on what could meet this causality 

requirement, the Court was crystal clear that some allegations would fall far short: ‘a plaintiff who 

fails to allege facts at the pleading stage or produce statistical evidence demonstrating a causal 

connection cannot make out a prima facie case of disparate impact.’” 759 F. App'x 828, 834 (11th 

7 To the contrary, in the vein of utility, and although Inclusive Communities does not make the 

provision of statistical evidence a necessary component of a prima facie case of disparate impact, 

Plaintiff offers statistical information to crystalize why Defendant’s practice regarding individuals 

it suspects to have been convicted of a felony has a disparate impact of Black and Hispanic 

individuals. See Supra at ¶¶ 10-11.

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Cir. 2018) (emphasis added) (citing Inclusive Communities at 2523). More pointedly, the Oviedo

court further stated: 

Even before the Supreme Court spoke to this question, this Court 

had arrived at similar conclusions, entirely consistent with Inclusive 

Communities, about the need for a relevant statistical showing in order 

to support a disparate-impact claim under the FHA, in [Schwarz v. City 

of Treasure Island, 544 F.3d 1201 (11th Cir. 2008)]. There, the plaintiff, 

who operated halfway houses for recovering substance abusers in the 

City of Treasure Island, Florida, had been cited by the City for violating 

a zoning ordinance that limited occupancy turnover. Id. at 1205. He sued 

the city under the FHA, alleging, among other things, that the zoning 

ordinance had a disparate impact on the rights of the disabled (the 

recovering substance abusers). Id. The claim failed because the 

plaintiff provided no comparative data to support his prima facie 

case. Id. at 1217-18. We held that in order to show disparate impact, the 

plaintiff must provide evidence comparing members of the 

protected class affected by the ordinance with non-members 

affected by the ordinance. See Id. at 1217. If the percentage of 

members of the protected class (recovering substance abusers) affected 

was higher than the percentage of nonmembers impacted, this 

disproportionality could form the basis for a prima facie case of 

disparate impact. The plaintiff in Schwarz had failed to provide an 

adequate statistical foundation because he presented “no comparative 

data at all,” but instead simply offered what we termed a “bald 

assumption” that the ordinance's effect on his houses meant that the 

handicapped had necessarily been disparately impacted. Id. at 1218.

Oviedo at 834-35. 

38. In terms of achieving the “robust causality” pleading requirement, Oviedo and 

Schwartz exemplify the threshold as the proffering of “evidence comparing members of the 

protected class affected by the [alleged discriminatory practice] with non-members affected by the 

[alleged discriminatory practice].” Oviedo at 835. Objectively, Plaintiff has met this threshold. 

Supra at ¶¶ 10-11. 

39. Simply put, due to the documented racial disparity in the criminal legal system, 

Defendant’s above-discussed prohibition on applicants with a felony conviction, by extension, 

disproportionately limits the housing opportunities of Hispanic and Black applicants in 

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comparison to White applicants, and in so doing, violates the Fair Housing Acts. See Sams v. GA 

W. Gate, LLC, 2017 U.S. Dist. LEXIS 13168, at *12-14 (S.D. Ga. Jan. 30, 2017) (denying motion 

to dismiss, concluding “that Plaintiffs have proffered sufficient evidence to survive a motion to 

dismiss. Plaintiffs have provided evidence that African Americans are twice as likely to have 

criminal convictions as are caucasians. Plaintiffs have also alleged that in 2014, African Americans 

represented 36% of the prison population in the United States but only 12% of the country's total 

population. As a result, Plaintiffs argue that Defendants' 99-year criminal history policy adversely 

affects African Americans because it adversely applies to Defendants' African American tenants. 

This is sufficient to avoid a motion to dismiss.” (citations omitted)).

COUNT I.

VIOLATION OF THE FAIR HOUSING ACT – 42 U.S.C. § 3604(d)

40. Plaintiff, the FFH Alliance, incorporates by reference paragraphs 1-39 of this First 

Amended Complaint as though fully stated herein.

41. Defendant is liable to Plaintiff for all injuries caused by the Fair Housing Act 

violations committed by Defendant and the agents of Defendant.

42. Defendant authorized its agents to act for it (Defendant) when Defendant’s agents 

committed the Fair Housing Act violations alleged herein. The agents of Defendant accepted the 

undertaking of acting on behalf of Defendant when they (Defendant’s agents) committed the Fair 

Housing Act violations alleged herein. Defendant had control over its (Defendant’s) agents when 

said agents committed the Fair Housing Act violations alleged herein.

43. Here, Defendant’s practice of, without any review or investigation, turning away 

individuals with (or merely suspected of having) a felony criminal record is an arbitrary and 

artificial barrier to housing, the likes of which is unnecessary to achieve a valid interest or 

legitimate objective. 

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44. A robust causal link exists between Defendant’s discussed practice of denying 

and/or steering away individuals it suspects to have been convicted of a felony and the disparate 

impact on Black and Hispanic people, as Black and Hispanic individuals are disproportionally 

more likely to have been convicted of a felony than that of white individuals. Defendant’s practice 

of denying, or otherwise without any review or investigation, turning away prospective individual 

it merely thinks was previously convicted of a felony has a direct, disproportionate discriminatory 

effect on Black and Hispanic individuals.

45. Defendant has violated the Fair Housing Act by, inter alia, making unavailable 

and/or otherwise denying the Dwelling to individuals on the basis of race and/or criminal record.

46. FFH Alliance has been aggrieved, harmed, and its (the FFH Alliance’s) goal 

otherwise thwarted, by above-exemplified latent discriminatory hurdle Defendant perpetuates – of 

which Defendant continues to practice despite such practices being explicitly condemned by HUD. 

See HUD Guidance (wherein HUD concluded that “a discriminatory effect resulting from a policy 

or practice that denies housing to anyone with a prior arrest or any kind of criminal conviction 

cannot be justified, and therefore such a practice would violate the Fair Housing Act.”). 

47. The FFH Alliance, having uncovered Defendant’s latent discriminatory practice 

and/or policy – has suffered damages in light of the FFH Alliance’s goals, purpose, and ongoing 

monitoring efforts. Further, due to Defendant’s conduct, the FFH Alliance’s has suffered, is 

continuing to suffer, and will in the future suffer, irreparable loss and injury and a real and 

immediate threat of future discrimination by Defendant.

48. WHEREFORE, Plaintiff FFH Alliance, respectfully, requests that this Court:

(a) Declare the above-mentioned actions, practices, omissions, polices, and 

procedures, of Defendant to be in violation of the Fair Housing Act;

(b) Award damages to Plaintiff against Defendant;

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(c) Enter a permanent injunction enjoining Defendant from using the steering 

practices complained of herein;

(d) Enter a permanent injunction compelling Defendant to amend its 

(Defendant’s) polices, Procedures, and practices, that have a disparaging 

impact on Black and Hispanic individuals; 

(e) Award Plaintiff costs and reasonable attorneys’ fees; and

(f) Any other relief that this Court deems appropriate and just under the 

circumstances.

DATED: August 10, 2020

Respectfully Submitted,

 /s/ Thomas Patti .

JIBRAEL S. HINDI, ESQ.

Florida Bar No.: 118259

E-mail: jibrael@jibraellaw.com

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

E-mail: tom@jibraellaw.com

The Law Offices of Jibrael S. Hindi

110 SE 6th Street, Suite 1744

Fort Lauderdale, Florida 33301

Phone: 954-907-1136

Fax: 855-529-9540

COUNSEL FOR PLAINTIFF

CERTIFICATE OF SERVICE

The undersigned certifies that on August 10, 2020, the forgoing was electronically via the 

Court’s CM/ECF system on all counsel of record. 

 /s/ Thomas J. Patti .

THOMAS J. PATTI, ESQ.

Florida Bar No.: 118377

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