UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

CIVIL COMPLAINT 

Brandon Ricardo Smith 

(Write the full name of each Plaintiff 

who is filing this complaint. If the 

names of all the plaintiffs cannot fit 

in the space above, please write 

"see attached" in the space and 

attach an additional page with the 

full list of names.) 

v. 

Campus Lodge Gainesville, 

Coastal Ridge Real Estate, 

(Write the full name of each Defendant 

who is being sued. If the names of all 

the Defendants cannot fit in the space 

above, please write "see attached" in 

the space and attach an additional 

page with the full list of names.) 

I --------------

NDFL Pro Se I (Rev. 12/16) Civil Complaint 

ClerkAdmin/Official/Forms 

Case No.: / ·. aoe-✓ I b ;r fttJ / i ,..1 

(To be filled in by the Clerk's Office) 

_ J,.-y Trial Requested? 

V'YES • NO 

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Case 1:20-cv-00168-AW-GRJ Document 1 Filed 07/31/20 Page 1 of 11
I. PARTIES TO THIS COMPLAINT 

A. Plaintiff(s) 

1. Plaintiffs Name: Brandon Ricardo Smith -----------------

Address: 2800 SW Williston Road, Unit 816 

City, State, and Zip Code: Gainesville, FL 32608 

Telephone: ______ (Home) 954-815-1220 (Cell) 

2. Plaintiffs Name: -----------------

Address: --------------------

City, State, and Zip Code: _____________ _ 

Telephone: _______ (Home) ________ (Cell) 

(Provide this information for any additional Plaintiffs in this case by 

attaching an additional page as needed.) 

B. Defendant( s) 

1. Defendant's Name: Campus Lodge Gainesville --------"'-----=----------

Name ofEmployer (if relevant): ___________ _ 

Address: 2800 SW Williston Road 

City, State, and Zip Code: Gainesville, FL 32608 

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2. Defendant's Name: __ C_o_a_s_t_al_R_id___.g....,_e_R_e_a_l_E_s_t_at_e __ _ 

Name of Employer (if relevant): ____________ _ 

Address: 80 E. Rich Street, Suite 120 

City, State, and Zip Code: Columbus, OH 43215 

3. Defendant's Name: -------------------

Name ofEmployer (if relevant): _ ____________ _ 

Address: ----------------------

City, State, and Zip Code: ______________ _ 

(Provide this information for any additional Defendants in this case by 

attaching additional pages as needed.) 

II. BASIS FOR JURISDICTION 

Federal courts have limited jurisdiction. Generally, only two types of cases 

may be heard in federal court: (1) a case involving a federal question or (2) 

case involving diversity of citizenship of the parties. A "federal question" 

case arises under the United States Constitution or federal laws or treaties. 28 

U.S.C. § 1331. A "diversity" case means a citizen of one State sues a citizen 

of another State or nation. No defendant may be a citizen of the same State as 

any Plaintiff in a diversity case, and the amount in controversy must be more 

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ClerkAdmin/Oflicial/Forms 3 

Case 1:20-cv-00168-AW-GRJ Document 1 Filed 07/31/20 Page 3 of 11
than $75,000. 28 U.S.C. § 1332. 

What is the basis for federal court jurisdiction? (check all that apply) 

VF ederal Question • Diversity of Citizenship 

Fill out the paragraphs in this section that apply to this case. 

A. If the Basis for Jurisdiction Is a Federal Question: 

List the specific federal statutes, federal treaties, and/or provisions of the 

United States Constitution that are at issue in this case: ------

Title VIII of the Civil Rights Act of 1968, 

(Fair Housing Act) 

B. If the Basis for Jurisdiction is Diversity of Citizenship: 

1. Plaintiff( s) 

a. Plaintiff is an individual and a citizen of: ---------

b. If any Plaintiff is a business or corporation, list the State where the 

business is incorporated _______ or has its principal 

place of business: ________________ _ 

(Note: Businesses/Corporations must be represented by counsel. 

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Case 1:20-cv-00168-AW-GRJ Document 1 Filed 07/31/20 Page 4 of 11
Attach additional page to provide this information for additional 

Plaintiffs.) 

2. Defendant( s) 

a. If the Defendant is an individual, identify their citizenship below. 

1. Defendant (name) 

is a citizen of (State) 

2. Defendant (name) 

is a citizen of (State) 

3. Defendant (name) 

is a citizen of (State) 

b. If the Defendant is a corporation or business, list the state of 

incorporation or principal place of business below. 

1. Defendant (name) -----------------

State of Incorporation is _____________ _ 

or Principal Place of Business is ___________ _ 

2. Defendant (name) ________________ _ 

State of Incorporation is ______________ _ 

or Principal Place of Business is ___________ _ 

(Attach additional page if necessary to list all Defendants.) 

3. Have you previously been involved in litigation with one or more 

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of the named Defendants? 

• Yes • No 

If yes, identify prior case#: Date: ------- -----

Court: 

Defendant: ---------------- ----

Judge: ------------------ ---

Result: - - -------------------

III. STATEMENT OF CLAIM 

Write a short and plain statement of your claim. Do not make legal 

arguments or quote from cases. State the facts which show what happened, 

as well as where and when it happened. State how each Defendant was 

involved and explain what a Defendant did or did not do; identify how each 

Defendant caused you harm or violated federal law. Write each statement in 

numbered paragraphs, limited as far as practicable to a single event or 

incident. If more than one claim is asserted, number each claim, and ensure 

that a short and plain statement of facts supporting each claim is included in 

the facts alleged. Attach no more than two (2) additional pages to state your 

claim. 

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Case 1:20-cv-00168-AW-GRJ Document 1 Filed 07/31/20 Page 6 of 11
IV. RELIEF REQUESTED 

State briefly and precisely what damages or other relief the plaintiff asks the 

court to order. Do not make legal arguments. Include any basis for claiming 

that the wrongs alleged are continuing at the present time. Include the 

amounts of any actual damages claimed for the acts alleged and the basis for 

these amounts. Include any punitive or exemplary damages claimed, the 

amounts, and the reasons you claim you are entitled to actual or punitive 

money damages. ____________________ _ 

V. CERTIFICATION 

As required by Federal Rule of Civil Procedure 11, I certify by signing below 

that to the best of my know ledge, information, and belief, this complaint: (1) 

is not being presented for an improper purpose, such as to harass, cause 

unnecessary delay, or needlessly increase the cost of litigation; (2) is 

supported by existing law or by a non-frivolous argument for extending, 

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Case 1:20-cv-00168-AW-GRJ Document 1 Filed 07/31/20 Page 7 of 11
modifying, or reversmg existing law; (3) the factual contentions have 

evidentiary support or, will likely have evidentiary support after a reasonable 

opportunity for further investigation or discovery; and (4) the complaint 

otherwise complies with the requirements of Rule 11. 

I agree to timely notify the Clerk's Office if there is any change to my 

mailing address. I understand that my failure to keep a current address on file 

with the Clerk's Office may result in the dismissal of my case. 

Date: 7 /27 /20 Plaintiffs Signature: __ 6- ______ 5~ __ 

.... __ _ 

Printed Name of Plaintiff: Brandon Ricardo Smith 

Address: 2800 SW Williston Road, Unit 816 

Gainesville, FL 32608 

E-Mail Address: bransmith3 0 5@gmail.com 

Telephone Number: 954-815-1220 

(Additional signature pages must be attached if there is more than one 

Plaintiff.) 

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Case 1:20-cv-00168-AW-GRJ Document 1 Filed 07/31/20 Page 8 of 11
UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

CIVIL COMPLAINT 

III. STATEMENT OF CLAIM 

Write a short and plain statement of your claim. Do not make legal arguments or quote from 

cases. State the facts which show what happened, as well as where and when it happened. State 

how each Defendant was involved and explain what a Defendant did or did not do; identify how 

each Defendant caused you harm or violated federal law. Write each statement in numbered 

paragraphs, limited as far as practicable to a single event or incident. If more than one claim is 

asserted, number each claim, and ensure that a short and plain statement of facts supporting each 

claim is included in the facts alleged. Attach no more than two (2) additional pages to state your 

claim. 

1. During my apartment tenancy and lease term; with Campus Lodge Gainesville 

(Apartment Complex) and Coastal Ridge Real Estate (Property Owner). I was racially 

discriminated against by both Defendants, as a Black man (African American). Campus 

Lodge Gainesville and Coastal Ridge Real Estate, racially discriminated against me by 

setting different terms, conditions, and/or privileges for rental of a dwelling unit for me; 

than other nonblack races were given .. As a Black man, Campus Lodge Gainesville and 

Coastal Ridge Real Estate charged me $615 per month, per room for a 2x2 unit - to 

lease my current apartment from August 1, 2020 to July 31 , 2021 . Totaling my rent 

$1 ,230. 

Case 1:20-cv-00168-AW-GRJ Document 1 Filed 07/31/20 Page 9 of 11
2. I personally spoke with a few other tenants of different races, who all live at Campus 

Lodge Gainesville as well - which were Asian, White, Hispanic, etc. and those tenants 

told me their rental rates wasn't $615 per month, per room; instead they signed leases to 

pay approximately $30 to $40 cheaper than my rent; for Fall 2020/2021 lease term .. 

Majority of those nonblack tenants of different races even told me they signed new lease 

agreements - from August 2020 to July 2021 , for only $574 per month; per room for a 

2x2 unit.. Those Asian, White, Hispanic, and other races of tenants are paying $41 lesser 

than what I signed for. As a Black man, my race was the cause of this housing 

discrimination. In which both, Campus Lodge Gainesville & Coastal Ridge Real Estate 

violated Title VIII of the Civil Rights Act of 1968, Fair Housing Act. 

IV. RELIEF REQUESTED 

State briefly and precisely what damages or other relief the plaintiff asks the court to order. 

Do not make legal arguments. Include any basis for claiming that the wrongs alleged are 

continuing at the present time. Include the amounts of any actual damages claimed for the acts 

alleged and the basis for these amounts. Include any punitive or exemplary damages claimed, the 

amounts, and the reasons you claim you are entitled to actual or punitive money damages. 

1. PUNITIVE DAMAGES: 

Plaintiff asks this Court to order the Defendants, to pay punitive damages. In the total sum of 

$265,000. Plaintiff seeks Punitive damages, in order for this Court to deter the named 

Defendants, from engaging in the same racial discriminatory conduct again in the future. 

With future tenants. 

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2. COMPENSATORY DAMAGES 

Plaintiff asks this Court to order the Defendants, to pay compensatory damages. In the total 

sum of $75,000. Plaintiff seeks compensatory damages from the named Defendants for loss 

of sleep, stress, fright & nightmares, & harassment. These symptoms and issues - prevented 

Plaintiff from fully enjoying his life. Which caused emotional distress. 

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