CHANGE IN DISPARATE IMPACT RULE WOULD JEOPARDIZE HOUSING SECURITY FOR MOST VULNERABLE CITIZENS

The Connecticut Fair Housing Center and other local fair housing groups throughout the nation have seen an increase in the number of people of color who have contacted the Center because they have been denied housing as the result of a criminal record.  This is not surprising since in Connecticut, African Americans are incarcerated at 9.4 times the rate of whites and Latinos are incarcerated at 3.9 times the rate of whites. African Americans comprise 41.6% of Connecticut’s prison population but only 9.7% of the total population.  Latinos comprise 26.2% of the prison population but only 14.7% of the overall population.[1]  As a result, people of color are denied housing more often than people who are white because of their criminal records.  The proliferation of tenant screening companies which gather data from many sources and provide them to landlords mean that more and more people with criminal records are being denied housing, not because they pose a threat to the safety of others today, but for behavior that in many cases is decades old.  A recent review of tenant selection policies in Fairfield County, Connecticut reveals that 78% of the units have rules that disqualify individuals with a criminal record.  Because of the disparity in conviction records in Connecticut and throughout the country, people of color are limited in their choice of where to live.

The disparate impact rule recognizes the inherent unfairness in limiting the housing choices for people of color based on a rule that sweeps too broadly.  One of the Center’s clients who is Latino was recently denied housing for an arrest for a misdemeanor that was eventually dismissed.  The client is now severely disabled and unable to move or act on his own, yet his criminal history prevented him from moving out of a nursing home and in with his mother for more than a year.  By using the disparate impact rule to challenge the use of criminal records, the Center has assisted this client, and many others, in obtaining housing that meets their needs without increasing the threat to the health or safety of other tenants. There is no need to weaken a regulation that is working to obtain housing for some of the country’s most vulnerable citizens.

[1] “State-by-State Data.” The Sentencing Project. Accessed Feb. 6, 2019. https://www.sentencingproject.org

Hartford Shelter Unlawfully Ejects an Individual with Disabilities from Shelter

 

 

 

IMMEDIATE RELEASE

July 15, 2019

Contacts: Greg Kirschner, Legal Director, greg@ctfairhousing.org or (860) 263 – 0724

Erin Kemple, Executive Director, erin@ctfairhousing.org or (860) 263 – 0723

 

Hartford Shelter Unlawfully Ejects an Individual with Disabilities from Shelter

South Park Inn claims that it caused former resident no harm when it forced him to sleep on the streets during cold and snowy weather for more than a week.

South Park Inn, a Hartford shelter and social services provider, argues in a new court filing that it can’t be held liable for harm suffered from unlawfully kicking residents onto the street in the winter because its clients “come and go from the shelter” and “[w]hen not at the shelter” “are out in the streets” “or are seeking or utilizing other refuge of myriad forms.”

The Connecticut Fair Housing Center filed suit against South Park Inn in March after the shelter suddenly expelled Zhakim Williams.  South Park Inn did not follow the State regulations before having Mr. Williams removed. Mr. Williams is an individual with disabilities who had been a shelter resident for six months. The employee who expelled Mr. Williams called the police and told the dispatcher that that she was kicking him out because Mr. Williams had threatened to “take her to a housing meeting” over how she was treating him. South Park Inn refused to readmit Mr. Williams and he spent more than a week on the streets during cold and snowy weather.

In addition to claiming that it is not foreseeable that a person who was formerly homelessness might be harmed by being made homeless again – in other words, that homeless people are so used to being homeless that they can’t be harmed by South Park’s conduct – South Park Inn also argues that state regulations for shelters do not create an enforceable standard of care for the protection of residents and the state and federal fair housing laws do not apply to it.

Mr. Williams eventually found a bed at another shelter with the help of the Center and the State Department of Housing, and has since moved into a transitional apartment. “I don’t want anyone to lose their job but I want South Park Inn to do better, train its staff better and treat its residents better,” said Mr. Williams when asked why he was pursuing this case.

Greg Kirschner the Center’s Legal Director stated “People who experience homelessness are no less human and no more immune to suffering from cruel and indifferent treatment or from the cold, hunger, and discomfort that comes with living on the streets. That South Park Inn, an institution which should know better than anyone of these challenges, would argue it has no duties to the people it serves and that its residents lack the dignity we accord to others is deeply troubling.”

Center staff attorney David Lavery added “from our preliminary investigation we expect to uncover that South Park Inn has acted with callous disregard for the emergency shelter regulations, has abused the 9-1-1 system to support its unlawful conduct, and has failed to protect the civil rights of its residents.”

 

We’re Hiring an Education & Outreach Coordinator

JOB ANNOUNCEMENT
COMMUNITY EDUCATION & OUTREACH COORDINATOR

Position Details:
The Connecticut Fair Housing Center seeks an innovative, energetic, and experienced
Community Education and Outreach Coordinator. This position will work closely with all staff,
and will be primarily responsible for organizing community-based legal education projects that
train and empower residents to assert their fair housing rights, building and maintaining
relationships with key allies and partners across the state, disseminating information about fair
housing and the work of the Center, and developing and implementing strategies to ensure that
the Center’s work is responsive to the concerns of target communities.
Specific Responsibilities Include:
• Coordinating community education projects including the development, marketing, and
delivery of fair housing trainings for the general public, community organizations, social
service agencies that work with those protected by the fair housing laws, and other target
populations;
• Building and maintaining new and existing partnerships with organizations working on
issues facing our clients, including tenants’ associations, grassroots community groups,
social services providers, advocacy organizations, and others;
• Building coalitions with other organizations to advocate for racial and economic justice,
homeowners’ and renters’ rights, disability rights, LGBTQIA+ equality, and other
transformative objectives;
• Attending community meetings and other public events to build relationships, raise the
Center’s profile and gather information about issues that may have fair housing implications;
• Soliciting input and feedback from community members, partner organizations, and former
clients to inform the Center’s work;
• Expanding the audience for the Center’s written materials;
• Seeking new ways to coordinate outreach and education between all staff members and
engage other staff in outreach and education efforts;
• Taking on other duties and responsibilities as assigned by the Executive Director.

Qualifications:
• Either a BA degree and 2 years of experience in community outreach, advocacy, training,
education, community organizing, or related field OR, AA degree, and 4 years of directly
related experience;
• Exceptional interpersonal skills; proven ability to cultivate relationships with and establish
networks among a diverse set of stakeholders, including clients, partner organizations,
community groups, etc.;
• Excellent verbal and written communication skills; public speaking/training experience
strongly preferred;
• Demonstrated interest in and passion for combating housing discrimination or other civil
rights violations, or related issues;
• Ability to work independently and take initiative;
• Ability to collaborate well with others;
• Proficient in Word and Excel; experience with other relevant software programs and with
managing social media accounts and/or websites helpful.
• Bi-lingual and/or bi-cultural individuals are strongly encouraged to apply.
• Must be willing and able to travel throughout CT for meetings, trainings, and other events
(mileage reimbursed).

Salary: Salary is highly competitive with other legal non-profits, with comprehensive benefit
package including exceptional health care, flex scheduling, and substantial paid leave.
$45,000 – $55,200 DOE.
Send resume and cover letter to: Letty Ortiz, Administrative Assistant at
letty@ctfairhousing.org. Please include a writing sample that reflects the applicant’s own work
without significant revision from others as well as the names and addresses of people who can
act as references. Please do not call.

Application Deadline: June 21, 2019
About Connecticut Fair Housing Center
The Connecticut Fair Housing Center is an equal opportunity employer.

We’re Hiring a Director of Operations

DIRECTOR OF OPERATIONS

JOB ANNOUNCEMENT

The Connecticut Fair Housing Center is a statewide nonprofit civil rights organization dedicated to ensuring that all people, and principally those with scarce financial resources, have equal access to housing opportunities in Connecticut, free from discrimination.  To accomplish our mission, the Center provides legal services to the victims of housing discrimination and those at risk of home foreclosure; conducts education, training, and outreach on fair housing laws; works with state and local governments to ensure compliance with the fair housing laws; and advocates for policies that will improve access to housing.

Position Details:

The Connecticut Fair Housing Center seeks an innovative, energetic, and experienced person to join the Center’s management team.  This is a new position for the Center as it seeks to enhance its financial stability and expand its programmatic reach across the state.  Reporting to and working closely with the Executive Director, the Director will be primarily responsible for resource development, financial oversight and assisting the Executive Director in expanding the organization’s reach.

Specific Responsibilities Include:

  • Financial management including creating the organizational budget, budgets for grants, and monitoring grant expenditures;
  • Working with the Center’s CPA firm to monitor the Center’s financial position and propose measures to increase the Center’s financial stability.
  • Grant research, writing, and reporting;
  • Researching and applying for new income sources;
  • Collaborating with the Executive Director to review programmatic results of the organization and assist in developing and implementing strategies to expand the reach of the organization;
  • Overseeing execution the Center’s annual Loving Civil Rights Award Dinner (including solicitation of sponsorship, ad support, and auction donations, managing event communications, event logistics, etc.).

Qualifications:

  • Bachelor’s degree and 5 years of organizational management or financial management experience;
  • Alternatively, a bachelor’s degree plus a degree in accounting or nonprofit management and 2 years of experience;
  • Experience in grant writing, grant reporting, and grant research;
  • Development experience including event planning or other types of fundraising;
  • Interest in combating housing discrimination/civil rights violations or related issues;
  • Ability to work independently and take initiative to lead projects and collaborate with others;
  • Proficient in Word, expert in Excel;
  • Bi-lingual and/or bi-cultural individuals are strongly encouraged to apply.

The Connecticut Fair Housing Center is an equal opportunity employer.

Salary:  Salary is highly competitive with other legal non-profits, with comprehensive benefit package.  $70,000 – 80,000 DOE.

Send resume and cover letter to:  Letty Ortiz, Administrative Assistant at letty@ctfairhousing.org.  Please include a writing sample that reflects the applicant’s own work without significant revision from others as well as three references.  Please do not call.

Application Deadline:  May 10, 2019

Landmark Civil Rights Decision

Federal Court Holds Tenant-Screening Services Must Comply with Fair Housing Act

On Monday, March 25, 2019 we received a landmark civil rights decision in our case against CoreLogic. In April of 2018 we filed suit with the National Housing Law Project alleging CrimSafe (CoreLogic’s tenant screening tool) discriminated on the basis of race, national origin, and disability in violation of the Fair Housing Act, after our client, a disabled Latino man with no criminal convictions was disqualified from moving in with his mother. The court rejected CoreLogic’s motion to dismiss, and held that because companies like CoreLogic functionally make rental admission decisions for landlords that use their services, they must make those decisions in accordance with fair housing requirements.  As automated decisions by third-party screening companies are rapidly becoming the norm, this ruling has significant implications for landlords, renters and the entire screening industry.

Over the past year, staff at the Center have worked on the Commission of Equity and Opportunity’s Re-Entry Task to propose legislation to reduce the barriers to housing encountered by individuals returning home from incarceration. Throughout this session in the Connecticut General Assembly the Center has advocated alongside the ACLU’s Smart Justice Campaign for legislative reforms to tenant screening processes. We are honored to contribute this decision to the greater cannon of civil rights work that is being done by so many Fair Housing advocates in Connecticut.

Please help us celebrate this victory at our Fair Housing Month reception at the Legislative Office Building on Wednesday, April 3rd, 5 pm -7pm in the first floor atrium. https://www.ctfairhousing.org/registerlob/

Read the full press release that includes links to our complaint and the court’s decision. CFHC v. Corelogic MTD March 2019

A Historic Fair Lending Settlement for Connecticut Residents

The Center is delighted to announce the settlement of the fair lending complaint against Liberty Bank. This historic settlement will bring more than $16 million dollars in access to credit, homeownership subsidies, and economic development loans into low and moderate income communities of color. Many of these communities have not had access to credit for home buying or for home repairs. Furthermore, small businesses have not had access to credit or capital to spur economic development in these communities. Included in the settlement, Liberty Bank will open a loan production office in a neighborhood that continues to be underserved by banking institutions.

We look forward to working with our partners in the communities that will be affected by this settlement to ensure its success. We applaud Liberty’s commitment of time, energy and resources to a wide range of programs that will help promote financial education, expand opportunities for access to credit, and financially support programs developed to revitalize the housing market in communities in Connecticut that have traditionally had difficulty accessing credit.

Our congratulations to Center staff, Attorney David Lavery and Fair Housing Specialist Maria Cuerda who worked the case. We are grateful for their commitment to pursuing fair lending practices across Connecticut in all communities regardless of race or national origin.

See coverage in today’s Hartford Courant 

Read the full press release here. Press Release Final – CFHC v Liberty Bank

Center, DOH hosting forums to present study on Mixed Populations in Housing

Myth vs. Reality: Mixed Populations in State-Funded Elderly/Disabled Housing, presenting a study by CT Fair Housing and the CT Department of Housing. Join us at upcoming forums in East Haven, Hartford, and Darien. Click on slider to learn more.

 

 

 

 

 

 

In 2017, the CT State Legislature requested a study of state-funded housing complexes that provide housing to both elderly tenants and younger tenants with disabilities.  The Center is partnering with the Connecticut Department of Housing to host three community forums around the state to present the findings of this study, separate myth from reality, identify best practices for handling areas of conflict, and discuss recommendations to ensure that state-funded elderly/disabled housing is available to all those who need it.

Join us at a forum near you:

East Haven
Tuesday, December 4th, 1-3pm at Hagaman Memorial Library (DeMayo Room) 227 Main Street, East Haven.  Limited parking is available in the library lot; additional parking is available on the street or in the adjacent Stop n’ Shop lot (please follow all signage).

Hartford
Thursday, December 6th, 10am-12pm at the Legislative Office Building – Hearing Room 1B

Darien
Friday, December 7th, 1-3pm – Darien Library (Louise Parker Berry Community Room), 1441 Post Road, Darien

Copies of the report will be distributed at each forum.  There will be time set aside for public comment at each event.  All locations are accessible.  Light refreshments will be provided in East Haven and Darien.

CLICK HERE TO REGISTER 

Read Full Report: A Study of Tenants in State-Funded Elderly/Disabled Housing  
View Report Appendices

Warning – Fake “Office Assistant” Job Posting

The Center recently discovered a fake job posting online for an “Office Assistant” position purportedly at the Center.  This appears to be a scam aimed at getting personal information from applicants.  The Center is not currently hiring for this position. We are investigating the matter and have requested that this posting be removed. In the meantime, if anyone contacts you regarding an Office Assistant or any other job at the Center, please call us at 860-247-4400 or email us at info@ctfairhousing.org.  Thank you!

Center & NCLC File Federal Lawsuit Accusing Liberty Bank of Redlining

The Connecticut Fair Housing Center and the National Consumer Law Center today filed a lawsuit in the U.S. District Court for the District of Connecticut against Liberty Bank, alleging that the bank has violated the Fair Housing Act by engaging in unlawful “redlining” of predominantly African-American and Latinx neighborhoods in the greater Hartford and New Haven metropolitan areas. “Redlining” is the discriminatory practice by banks or other financial institutions of denying or avoiding providing credit services to consumers because of the racial or ethnic demographics of their neighborhoods.

The Fair Housing Act prohibits financial institutions from discriminating on the basis of race and color in their mortgage lending practices. The complaint alleges that Liberty Bank has structured its residential mortgage lending business in such a way as to avoid serving the credit needs of Connecticut neighborhoods where a majority of residents are African-American and/or Latinx.

The bank’s alleged redlining practices include: excluding African-American and Latinx neighborhoods from the area it serves; intentionally locating branch offices and mortgage loan officers in only majority-white neighborhoods; and engaging in differential treatment of prospective loan applicants on the basis of race or ethnicity. An investigation by the Connecticut Fair Housing Center revealed that, going back to at least 2010, Liberty Bank has originated a significantly lower percentage of residential mortgage loans for properties in neighborhoods of color when compared with similar lenders.

“Redlining systematically denies people who live in neighborhoods of color access to homeownership, therefore denying them the opportunity to build wealth,” said Connecticut Fair Housing Center Executive Director Erin Kemple. “Unfortunately, fifty years after the passage of the Fair Housing Act, the practice continues. Liberty Bank is choosing to offer less assistance to communities of color in violation of the state and federal fair housing laws.”

“Liberty Bank’s practices and timing are particularly disturbing in light of the continuing impact of the Great Recession on households of color in Connecticut and around the nation,” said National Consumer Law Center Director of Litigation Stuart Rossman. “Latinx families lost 66 percent of their wealth and African American families lost 53 percent of their wealth compared to 16 percent loss of wealth for White families. Depriving equal access to mortgage credit exacerbates the continually growing racial economic gaps in our society and perpetuates the very segregation in our neighborhoods that the Fair Housing Act was meant to reduce, if
not eliminate.”

Click here for a copy of the complaint

 

Media coverage of this case:

Southington branch included in lawsuit alleging housing bias by Liberty Bank (Meriden Record-Journal, October 11, 2018)
Nonprofits File Federal Housing Lawsuit Against Liberty Bank (CTNewsJunkie, October 8, 2018)
CT Bank Sued for Alleged Discriminatory Mortgage Lending (National Law Review, October 9, 2018)
2 Consumer Groups Hit Conn. Bank With Redlining Suit (Law360, October 5, 2018)
Discrimination Against Customers Alleged in Liberty Bank Federal Suit (Connecticut Law Tribune, October 5, 2018)
Liberty Bank Accused of Racial Discrimination in Lending Practices (Hartford Courant, October 4, 2018)
Liberty Bank Accused of Racial Discrimination in Lending Practices (NY Daily News, October 4, 2018)
Lawsuit alleges discriminatory lending practices by Liberty Bank (Hartford Business Journal, October 4, 2018)

Center Files Federal Lawsuit Against National Tenant Screening Company

Arroyo v. CoreLogic seeks to establish precedent that screening companies must comply with Fair Housing Act

The Connecticut Fair Housing Center and the National Housing Law Project have filed a new lawsuit in the U.S. District Court for the District of Connecticut contending that CoreLogic Rental Property Solutions (“CoreLogic”) violates the Fair Housing Act by disproportionately disqualifying African-American and Latino applicants from securing housing based on discriminatory use of criminal records as rental criteria.Laptop with hands typing.

The lawsuit asserts that CoreLogic’s tenant screening tool denied a Connecticut mother’s request to move her disabled son into her apartment based on a record of a dismissed shoplifting arrest from 2014.  Although rental decisions have traditionally been made by housing providers, today many landlords contract with third-party tenant-screeners to make admission decisions for them.  This litigation seeks to ensure that CoreLogic and all tenant-screening companies who functionally make rental decisions on behalf of landlords make those decisions in accordance with fair housing requirements.

The chief plaintiff in the lawsuit is Carmen Arroyo, whose son Mikhail was injured in a July 2015 accident that left him unable to speak, walk, or care for himself.  After becoming his conservator, Carmen asked her landlord for permission to move Mikhail into her home.  But the “CrimSAFE” background report from CoreLogic stated that Mikhail had a “disqualifying [criminal] record,” denying him the opportunity to move in with his mother.

Given that Mikhail’s only “criminal record” was the dismissed charge from 2014 and that his recent disabilities rendered him incapable of posing a threat to anyone, Carmen might have been able to challenge the denial.  However, CoreLogic refused to provide the Arroyos a copy of the information it relied on to make the screening decision, information which they were entitled to receive under federal law.[1]  Nor did CoreLogic’s criminal background report provide any details about Mikhail’s underlying criminal history to the landlord—only a computer-generated notation that the application did not meet the landlord’s criteria.  Without this information, the Arroyos could not challenge Mikhail’s denial, so he remained in a nursing home for approximately a year longer than necessary.

The Fair Housing Act prohibits denying tenants on the basis of race, color, religion, sex, familial status, national origin, or disability including practices and policies that unnecessarily disproportionately exclude members of a protected class.

Between 70 million and 100 million Americans have criminal records. Multiple studies have shown that across the country, African-Americans and Latinos are arrested, convicted, and incarcerated at disproportionate rates, even though whites report engaging in criminal behaviors (such as drug offenses, which account for over half of federal incarcerations) at similar rates to non-whites. [2],[3],[4],[5] This means policies which restrict admission for applicants with criminal records disproportionately deny housing opportunities to people of color.[6]  The federal government recognized this when HUD issued a 2016 guidance for landlords on how to evaluate criminal histories in accordance with the law.

This means that only criminal records which suggest an applicant poses a genuine and ongoing threat to persons or property should result in denial.[7]  HUD’s guidance specifically advises not to deny admission based on dismissed arrests – like Mr. Arroyo’s – or through “blanket prohibitions” that exclude applicants with any kind of criminal record without regard to the nature of the offense, how long ago it occurred, intervening changed circumstances, and other relevant factors.[8]

Instead, admissions processes should generally consider criminal records on a case-by-case basis.[9]   Automated criminal background checks with computer-generated scores and decisions—like CoreLogic’s “CrimSAFE”—are ill-suited to perform individualized assessments of applicant criminal history.  Tenant-screening software is programmed to apply standard rental admission criteria to criminal records data appearing in an applicant’s background check; the software does not evaluate whether an offense bears a meaningful relationship to housing, whether changed circumstances may significantly reduce the likelihood of an offense being repeated, or the myriad other possible factors that may relate to a criminal history admission decision.

Even so, automated tenant-screening methods—including for criminal history—are rapidly becoming the norm in rental admission screening.  Landlords commonly rely on the screening company’s determination of suitability, often—as with Carmen Arroyo’s landlord—not even receiving the underlying background information they would need to evaluate applicants individually.  Allowing computers to effectively make rental decisions will inevitably produce unjust denials for applicants like the Arroyos, whose circumstances do not fit neatly into pre-programmed screening algorithms.

A housing provider who blindly follows a screening company’s denial recommendations and has no viable process for individualized review or reconsideration thus follows a discriminatory policy under the Fair Housing Act.[10]  But the Fair Housing Act does not only apply to housing providers – it also covers individuals and companies who provide services in connection with housing, such as tenant-screening reports.[11]  When a tenant-screening company markets a criminal background report that contains only a bare “accept” or “decline” determination, and does not make underlying criminal history information available to allow a landlord to make an individualized assessment of a rejected applicant, the screening company’s “recommendation” is tantamount to the actual admission decision.

And if a tenant-screening company is going to make the actual decisions about who is admitted to housing and who is denied, then it’s important for that company to make those decisions within fair housing constraints, just as we expect landlords to do.

Ms. Arroyo and the Center, together with the National Housing Law Project, have brought an action seeking to hold CoreLogic accountable for its role in unlawfully denying housing to Mikhail Arroyo based on a discriminatory criminal records policy, and for failing to provide the Arroyos a copy of the criminal background report as required by federal law. This litigation seeks to ensure that CoreLogic and all tenant-screening companies follow fair housing requirements when they functionally make rental decisions on behalf of landlords make those decisions in accordance with fair housing requirements.

To read the Complaint, click here.

For questions about this case, please contact Greg Kirschner, Legal Director, at greg@ctfairhousing.org or (860) 263-0724.

 

[1] See 15 U.S.C. § 1681g(a) (“Every consumer reporting agency shall, upon request … clearly and accurately disclose to the consumer:  (1) All information in the consumer’s file at the time of the request…”).

[2] See, e.g., Alexander, Michelle, The New Jim Crow: Mass Incarceration in the Age of Colorblindness (2010).

[3] See HUD, 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, p. 2 (Apr. 4, 2016).

[4] Taxy, Sam, et al., “Drug Offenders in Federal Prison: Estimates of Characteristics Based on Linked Data,” p. 2 (Table 1), Bureau of Justice Statistics (2015).

[5] See HUD, 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, p. 2 (Apr. 4, 2016).

[6] See HUD, 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, p. 2 (Apr. 4, 2016).

[7] See HUD, 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, p. 2 (Apr. 4, 2016).

[8] HUD, 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, p. 6 (Apr. 4, 2016).

[9] Id. at 7 (“Relevant individualized evidence might include: the facts or circumstances surrounding the criminal conduct; the age of the individual at the time of the conduct; evidence that the individual has maintained a good tenant history before and/or after the conviction or conduct; and evidence of rehabilitation efforts.”).

[10] See 24 C.F.R. § 100.500(b) (defining “legally sufficient justification”); see also HUD, 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, pp. 6-7 (Apr. 4, 2016).

[11] See 42 U.S.C. § 3604(a)(b) (unlawful “to discriminate against any person in the terms, conditions, or privileges of sale or rental of a dwelling, or in the provision of services or facilities in connection therewith, because of race, color, religion, sex, familial status, or national origin”) (italics added).

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