emotional harm in housing discrimination cases

Much of the discussion in this section relies on judicial precedent developed in private plaintiffs intent claims for damages, and therefore focuses on standards applied in that context. A .gov website belongs to an official government organization in the United States. See, e.g., Melendres v. Arpaio, 695 F.3d 990 (9th Cir. Id. UDAP statutes (state statutes of general applicability prohibiting unfair or deceptive practices) allow for emotional distress damages, except for the few statutes that explicitly exclude such recovery. v. Seattle Sch. In a case alleging such pervasive or systemic discrimination, the plaintiff need not initially show discrimination against any particular person; rather the critical showing at the prima facie stage is one of a pervasive policy of intentional discrimination affecting many individuals. 1143, 1157 (2003) ([M]any victims must rely on their emotional harm claim as their primary basis for economic compensation.). The ECOA, FHA, and 1981 explicitly provide for punitive damages, and many cases have found emotional distress damages available under those statutes as well. Liability in private suits for monetary damages involving student-on-student harassment lies only where the funding recipient acts with deliberate indifference to known acts of harassment in its programs or activities. Davis v. Monroe Cty. 28, 2022), a deaf and legally blind individual was denied a sign language translator when receiving physical therapy services. 2005)); Mickelson v. N.Y. Life Ins. 2007), a case originally brought under, investigations, evaluation of these factors demands, Critically, Arlington Heights directs courts and agencies to, legislature in violation of the Fourteenth, v. McCrory, 831 F.3d 204 (4th Cir. WASHINGTON Dividing 6 to 3 along ideological lines, the Supreme Court ruled on Thursday that victims of discrimination that is forbidden by four federal statutes may not sue if the only harm was emotional distress. 1, 551 U.S. 701 (2007) (distinguishing between race conscious mechanisms to achieve diversity in public schools, such as strategic site selection of new schools, and approaches that treat specific individuals differently based on race); see also Doe ex rel. 1681 et seq. Croson Co., 488 U.S. 469, 493 (1989), and Adarand Constructors, Inc., v. Pena, 515 U.S. 200, 226 (1995), established that any intentional use of race, whether for malicious or benign motives, is subject to the most careful judicial scrutiny. The two main ways to prove emotional distress damages are (1) for the employee (and their friends and family) to testify about how the discrimination caused at 295; see also Johnson v. California, 543 U.S. 499, 50506 (2005) (racial classifications for penological purposes, such as controlling gang activity in prison, subject to strict scrutiny); United States v. Brignoni-Ponce, 422 U.S. 873, 88587 (1975) (law enforcement need does not justify stopping all Mexican-Americans to ask if they are aliens). Kim naj lewaj juon am dri ukok eo ejjelok wonen. Many laws that prohibit employment discrimination, such as Title VII of the 1964 Civil Rights Act and the Americans with Disabilities Act (ADA), permit employees to recover money damages for the pain and suffering caused by their employers discrimination against them. Agencies investigating complaints alleging widespread discrimination may find useful guidance in Title VII case law that discusses pattern or practice discrimination. Accordingly, when viewed collectively, the evidence in the record established intentional discrimination based on race. The ECOA, FHA, and 1981 explicitly provide for punitive damages, and many cases have found emotional distress damages available under those statutes as 2006) (addressing a Title VII race discrimination claim). This type of direct evidence of discriminatory intent does not require a virtual admission of illegality. Venters, 123 F.3d at 973. Waters of the United States and Winston Churchill. Primacks text messages included multiple threats to strangle, punch, and inflict pain on Boyd, belittled her gender identity and expression, and contained gender-based slurs. Circumstantial evidence, also known as indirect evidence, requires the fact finder to make an inference or presumption. White also said it is essential for others to understand the role these animals play in their lives. It can be subtle, friendly, and difficult to pin down. By analogy, he wrote, people suing businesses that accept federal money cannot win such damages, either. Proof of Systemic or Wide-Spread Discrimination (Pattern or Practice Discrimination). As EPA continues to move toward identifying PFAS as Hazardous Is an OSHA Workplace Violence Standard for the Healthcare Industry on Yellen Calls on World Bank to Take Decisive Action on Climate Change, To Volunteer or Not: The Role of Community Association Board Members. of NAACP v. McCrory, 831 F.3d 204 (4th Cir. But the Court clearly acknowledges the availability of contract emotional distress damages in certain contexts. Victor Goode, CUNY School of Law Conrad Johnson, Columbia University School of Law. Amamos lo que hacemos y nos encanta poder seguir construyendo y emprendiendo sueos junto a ustedes brindndoles nuestra experiencia de ms de 20 aos siendo pioneros en el desarrollo de estos canales! Grifos, Columnas,Refrigeracin y mucho mas Vende Lo Que Quieras, Cuando Quieras, Donde Quieras 24-7. Ogletree, Deakins, Nash, Smoak & Stewart, P.C. You have the right to an interpreter at no cost to you. Copyright 2023, State of Hawaii. Aerospace & Agric. Accordingly, non-statistical evidence of harm to minorities and non-minorities that is significantly different will be relevant evidence in an Arlington Heights case. Its Here The New National Cybersecurity Strategy. Housing Discrimination: Types, Examples, and Actions to Take. Nevertheless, many recent commentators have agreed that few areas of the law have failed to achieve their lofty goals as dramatically and persistently as our nation's fair housing statutes. This implies that proving the existence of discriminatory behavior against a protected class will be a difficult task. 1987) (suggesting that courts may require, in addition to statistical significance, that the observed disparity be substantial). Webcases. Webplaintiffs in fair housing cases, noneconomic emotional harm or other forms of intangible injury. Corp. v. Calvert Cty., 48 F.3d 810, 819 (4th Cir. However, statistical evidence, while extremely beneficial, is not a necessity in impact cases. Get browser notifications for breaking news, live events, and exclusive reporting. [18] Dep't of Justice and Dep/'t of Educ., "Dear Collegue" Letter on the Nondiscriminatory Administration of School Discipline (Jan. 8, 2014), available at http://www2.ed.gov/about/offices/list/ocr/letters/colleague-201401-title-vi.html. of Univ. 149, 177 (2012) ([S]tray remarks can prove to be invaluable insights into biases at every level of consciousness that may be rife but invisible within the workplace. [They] may bespeak a workplace culture in which certain language or sentiments are tolerated and perhaps encouraged or rewarded.)). [1] Unlike when seeking judicial enforcement, private parties may file administrative complaints under any theory of liability, including disparate impact. of Cal. Maquinas Vending tradicionales de snacks, bebidas, golosinas, alimentos o lo que tu desees. Nuevos Medios de Pago, Ms Flujos de Caja. The content and links on www.NatLawReview.comare intended for general information purposes only. Improvement v. City of Modesto, 583 F.3d 690 (9th Cir. While Title VI does not expressly include a pattern or practice claim, principles developed in these contexts and discussed below can nevertheless inform the investigation and analysis of Title VI claims. A plaintiff or agency investigation can use statistics in several ways to establish a claim of intentional discrimination. Accepting Cryptocurrency and Digital Asset Donations: What Charities Need to Know. All rights reserved. However, "[w]hen one type of evidence is missing altogether, the other must be correspondingly stronger for plaintiffs to meet their burden." The Cummings opinion then surveys contract law to determine whether an entity breaching its agreement with the federal government would be on notice that it would be liable for emotional distress damages for its breach of contract. Nonetheless, it is categorically prohibited in light of the broader ban on discrimination based on familial status. Splitting 6 to 3, the court ruled that facilities receiving federal money cannot be sued under four federal laws for discrimination that causes emotional distress. L. Rev. 2006). View DLIR news releases: The court in Venters explained that the evidence need not be this obvious to qualify as direct evidence. Id. Generally, emotional distress lawsuits allow employees who have suffered discrimination or retaliation to recover monetary damages for the pain and suffering caused by the unlawful conduct. Just like there is age discrimination in the workplace, housing discriminates against certain age groups, as well. 426 U.S. 229, 242 (1976) (discussing analysis of, based on race, color, or national origin. HONOLULU The Hawaii Civil Rights Commission today announced that it issued a final decision and order in a housing discrimination case on November 30, 2018. This evidence, which included conduct or statements by persons involved directly reflecting the discriminatory attitude, constitutes direct evidence of discriminatory animus. Id. Private parties may also file administrative complaints with federal agencies alleging that a recipient of the agencys federal financial assistance has engaged in intentional discrimination; the federal agency providing the assistance may investigate these complaints.[1]. See, e.g., Bazemore v. Friday, 478 U.S. 385, 400 (1986) (observing the usefulness of multiple regression analysis, even one that did not include all measurable variables). This is discussed more extensively beginning at page 30. Bd., 731 F.2d 465, 470 (8th Cir. 1995), a Title VII case, a female plaintiff alleged that she was not promoted because of her sex. Ikkandakayo iti libre nga paraipatarus. His son A.J. Teamsters, 431 U.S. at 360 & n.46. Someassume that the intentional use of race should be carefully scrutinized only when the intent is to harm a group or an individual defined by race, color, or national origin. WebCompounding the problem is the difficulty of measuring the principal element of damages claimed by most plaintiffs in fair housing cases, noneconomic emotional harm or other No. Litigation Setback for Employers Under Illinois Biometric Information Senate Committee Holds Hearing on Future of Low Carbon Transportation North Carolina Senate Passes Compassionate Care Act at Exactly 4:20 States and Feds Signal Big Changes to Telehealth Prescribing. [7] Plaintiffs use this framework, originally developed for Title VII employment cases, to show that a defendant treated similarly situated individuals differently because of race, color, or national origin. NCLC works with nonprofit and legal services organizations, private attorneys, policymakers, and federal and state government and courts across the nation to stop exploitativepractices, help financially stressed families build and retain wealth, and advance economic fairness. The level or degree of impact that a plaintiff alleging discriminatory intent must show depends on a variety of factors, including the strength of the impact evidence and the strength of other indicators of intent under Arlington Heights. Attorney Advertising Notice: Prior results do not guarantee a similar outcome. 30 White. Necesita ayuda en otro idioma? Landlords and property developers must take reasonable steps to accommodate the needs of people with disabilities, and homeowners' associations must make reasonable accommodations for vulnerable groups. After all, decision-makers seldom will admit that they based decisions on race or ethnic origin, or used either as a criterion. Boyds fair housing complaint alleged that Primack harassed, threatened, and forced her off the subject property after he saw her expressing her gender identity for the first time in person. And discrimination based on race, color, national origin, sex, age or disability is particularly likely to cause serious emotional harm.. See Parents Involved in Cmty. Both families have residents with a mental health disability, an invisible disability that makes it difficult for others to understand and offer the appropriate services. See, e.g., SECSYS, LLC v. Vigil, 666 F.3d 678, 686 (10th Cir. The Department of Education's Office for Civil Rights is also available to provide assistance about the use of race in the educational context. Llame al (808-586-8844) y diganos que idioma habla. Since its adoption over thirty years ago, lower courts have mainly adopted an interpretation of the Fair Housing Act that reflects an effort to fulfill its broad legislative purpose. So White contacted the Rathod Mohamedbhai Law Firm and started working with attorney Laura Wolf. ", First published on June 5, 2019 / 12:15 PM. If you would ike to contact us via email please click here. implausibilities, inconsistencies, incoherencies, , 460 F.3d 1304, 1315 (10th Cir. For example, were a written test used to determine eligibility for a federally funded benefit or program, and the test resulted in a much higher percentage of minorities than non-minorities being determined ineligible for the benefit or access to the program, that might present a case of systemic discrimination. Compare Chisholm v. USPS, 665 F.2d 482, 495 (4th Cir. Alexander v. Sandoval, 532 U.S. 275, 28081 (2001). [In employment cases,] [w]here the overall nunber of employees in small, anecdotal evidence may suffice." Parents Involved, 551 U.S. at 720. Justice Department Announces Application Form for Marijuana Pardon Certificates, HERE IT IS: The Czars HUGE Breakdown of the FCC NPRM is NOW AVAILABLE to Everyone. 5512-01 (Jan. 19, 2001). (808) 586-8845 Share. 1994) (citing Feeney). Athletic Assn, 43 F.3d 265, 276 (6th Cir. Tumawag sa (808-586-8844) para sabihin kung anong lengguwahe ang nais ninyong gamitin. These kinds of requirements are often referred to as express classifications, and are the clearest form of direct evidence. AG Clamps Down on Local Solar and Battery Storage Moratoria. Indeed, victims of intentional discrimination may sometimes suffer profound emotional injury without any attendant pecuniary harms. Prot., No. Makemake la maua i ki`i `oe mea unuhi manuahi. "I'm from New Jersey, there's three things you don't mess with, that's my family, my job and my home," White said. See, e.g., Brewer v. Bd. ______________________________________________________________________________________________________________________. Complaint. Supreme Court Clarifies the Meaning Salary Basis Under Federal OIRA Calls for Feedback on Recommendations to Encourage More FTCs One-Two Punch on Data Tracking and Health Privacy. Although the name is self-explanatory, emotional distress damages can cover a range of harms, including: diagnosed psychiatric condition (such as depression or anxiety disorder); loss of enjoyment of life and mental anguish; strained relationships with family and friends. For example, in the employment context, a defendant may not merely state that the employment decision was based on the hiring of the best qualified applicant, but must provide specifics regarding that applicants qualifications, such as seniority, length of service in the same position, personal characteristics, general education, or experience in comparable work, and must demonstrate why that persons qualifications were considered superior to those of the plaintiff. Agencies and plaintiffs can use them individually or together and may combine both direct and circumstantial evidence. This includes refusing to sell a house to someone based on race, national origin, religion, gender, sexual orientation, disability, or family status. The facility refused, saying Ms. Cummings could communicate with her therapist using notes, lip reading or gestures. . The first Arlington Heights factor, statistics demonstrating a clear pattern of discriminatory effect, acknowledges that disparate impact evidence can be probative of discriminatory intent. 1994); accord, Pitre v. Western Elec. 1, 551 U.S. 701, 720 (2007) ([W]hen the government distributes burdens or benefits on the basis of individual racial classifications, that action is reviewed under strict scrutiny.); Gratz v. Bollinger, 539 U.S. 244, 270 (2003) (applying strict scrutiny to student admissions policies that considered race as a factor). In many cases, including many litigated under Arlington Heights, evidence will show that an ostensibly race-neutral practice has had a much more harmful effect on minorities than on non-minorities. WebIn most discrimination cases, the injury to feelings compensation covers impact on your health. 2010) (expressing support for using discriminatory impact, foreseeable consequences, and historical background to demonstrate intent in enacting mandatory minimums for crack cocaine, but determining that court could not find intentional discrimination where Second Circuit already made finding on the specific issue under consideration). 1079, 1084 (W.D.N.Y. 1988); Haskell v. Kaman Corp., 743 F.2d. In other cases, landlord discrimination may result in higher rents or deposits for tenants with disabilities. Marie v. E. R.R. Strict scrutiny requires that the decision-maker ultimately be satisfied that no workable race-neutral alternatives would further the compelling interest about as well and at tolerable administrative expense. Fisher v. Univ. Feb. 23, 2015) (Title VI case citing Pac. TDD/TTY Dial 711 then ask for (808) 586-8866. [16]The elements of a prima facia case are the same under both Title VI and VII. A clean direct evidence casewhere direct evidence alone establishes that discrimination was the sole reason for an adverse decisionis rare. By 26 May 2022 usc marshall drop in advising 26 May 2022 usc marshall drop in advising 1982). When trying to calculate if emotional distress damages are warranted and in what amount, a jury will consider: the severity of the discrimination/harassment; the duration of the discrimination/harassment; the severity and duration of the emotional harm; and, whether one sought professional treatment for the emotional distress (from a psychiatrist, psychologist, counselor, etc.). Vili mai i le numera lea (808-586-8844) pea e manao mia se fesosoani mo se faaliliu upu. Constitutional Law Commons, Home | The U.S. Court of Appeals for the Fifth Circuit, in New Orleans, affirmed that ruling. Arlington Heights, 429 U.S. at 26668, and its progeny set forth a variety of factors probative of intent to discriminate. 1998). [19]. at 233. An agency need not use the same sequential process as courts, where a plaintiff first offers prima facie evidence and the defendant then offers rebuttal evidence. at 339 n.20. The Fair Housing Act was passed in 1968 in the aftermath of Dr. Martin Luther King, Jr.'s assassination and as an extension of the Civil Rights Act of 1964; it has been amended several times since then. Similarly, Title VI requires recipients to demonstrate that any intentional use of race, color, or national origin classification is narrowly tailored to achieve a compelling government interest. Agency regulations further state that recipients may not administer their programs or activities in a manner that den[ies] any individual any disposition, service, financial aid, or benefit provided under the program, 28 C.F.R. v. Feeney, 442 U.S. 256, 279 (1979). See also NCLCs Federal Deception Law 7.4.3.5, 7.4.3.6 (Telephone Consumer Protection Act claims with standing in federal court). v. Penick, 443 U.S. 449, 46465 (1979); see United States v. Brown, 561 F.3d 420, 433 (5th Cir. Discrimination in housing is defined as any type of discrimination that occurs when a person attempts to purchase, rent, or lease a home. [21] However, "[t]here is no minimum statistical threshold" mandating that plaintiff has demonstrated a violation. Cummings clearly does not affect the availability of emotional distress damages for statutory violations not involving discrimination law and whose legislative authority is not based on the Spending Clause. Shores Props., 730 F.3d at 1159. Dist. Part I provides an overview of the current state of emotional harm cases. 2000d. According to the National Fair Housing Alliance research, complaints alleging disability discrimination continue to account for the majority of disputes, while race-based discrimination accounts for nearly 20% of them. No. Webhumboldt county murders 2020 emotional harm in housing discrimination cases. of Educ., 766 F.2d 917, 929 (6th Cir. of Trs. Accordingly, the discriminatory impact of a facially neutral policy or practice (frequently, but not always, demonstrated through the use of statistics) can be used as part of the evidentiary showing in an intentional discrimination case. Discrimination in housing is the illegal practice of treating people differently based on their protected class when renting, selling, financing, or advertising housing. Cummings directly controls the availability of emotional distress damages under four federal discrimination statutesthe only federal discrimination statutes whose authority is based on the Spending Clause: Congressional authority for other federal discrimination statutes, such as the Equal Credit Opportunity Act (ECOA), the Fair Housing Act (FHA), and 42 U.S.C. 2008); Fitzgerald v. Action, Inc., 521 F.3d 867, 877 (8th Cir. This language is best read to encompass a broad range of adverse actions that may be caused by a recipients administration of its program. Free Speech Shines Bright, Illuminates Patent Owners Right to Allege California Supreme Court to Address Rounding of Employee Time. Here, the McDonnell-Douglas burden- shifting test that applies in litigation to determine whether an institution has engaged in intentional discrimination does not necessarily apply in the context of agency enforcement activities prior to administrative litigation. "I read the pet policy, I saw some of the statements in it, and I said this pet policy is not fair," Lonnie White said over the phone to CBS4. Often, but not always, termed deliberate indifference cases, the standard of proof has been most commonly applied to harassment claims, particularly sex- and race-based claims. tippah county news. Telehealth Update: DEA Issues Long-Awaited Proposed Rule on Prescribing Controlled Navigating the FCC's Universal Service Program: Compliance Requirements for Service Providers, Financial Services: Use of Limitation-of-Liability Clauses in Fiduciary Relationships. Waisome v. Port Auth. Justice and Commerce Departments Announce Creation of Disruptive United States Department of Justice (DOJ), Biden Executive Order 14091 Strengthens Equity for Federal Agencies. 2005). As stated by Senator Walter Mondale, one of its sponsors, the Act would replace the nation's ghettos by "truly integrated and balanced living patterns." N.C. State Conf. Ill. 1995), affd, 87 F.3d 916 (7th Cir. Agencies should be sure to consider this method where a complaint challenges an expressly neutral policy or practice that has an effect on a larger class defined by race, color, or national origin. As such, and in most instances, the question whether the facts proved are sufficient to permit a legal inference of discriminatory intent cannot properly be reduced into a mere battle of statistics. Gay, 694 F.2d at 552. "Like most depressed people, when they're depressed, they don't want to do anything, just getting out of bed is hard," he said of his son. v. United States, 433 U.S. 299, 30708 (1977) (Where gross statistical disparities can be shown, they alone may in a proper case constitute prima facie proof of a pattern or practice of discrimination.). 2009). Tawag sa (808-586-8844) aron magpahibalo kung unsa ang imong sinulti-han. Teamsters, 431 U.S. at 336; Hazelwood, 433 U.S. at 307. the legislatures passage of the challenged provisions, Arlington Heights, 429 U.S. at 266 (discussing the importance of. [20] Statistical evidence can sometimes serve by itself to establish a prima facie case in the pattern or practice context, in lieu of comparative evidence pertaining to each class member. Furthermore, individuals who engage in discriminatory housing practices, or knowingly aid or abet such discrimination, may face criminal charges dictated by federal law. Servs., Inc., 161 F.3d 1318, 1330 (11th Cir. Document Type. See Melendres v. Arpaio, 989 F. Supp. of N.Y. & N.J., 685 F.3d 135, 147 (2d Cir. Desperate Times, Desperate Measuring Cups FTC Brings Enforcement Trending in Telehealth: February 20 26, 2023, IRS Sets Deadline For Using 401(K) Plan Forfeitures, How Generative AI Generates Legal Issues in the Games Industry, DOJ Announces New Nationwide Voluntary Self-Disclosure Policy. 4. No. [17] The DOJ regulations quoted here are similar to those of other agencies. My Account | Unfortunately, landlords in the United States may attempt to evict tenants with disabilities, refuse to make necessary repairs, or add accessibility features to their units. HERE IT IS: The Czars HUGE Breakdown of the FCC NPRM is NOW Telehealth Update: DEA Issues Long-Awaited Proposed Rule on CFPB Provides Guidance on Auto Finance Data Pilot, Two Maui Men Sentenced for Racially Motivated Attack on White Man, US Executive Branch Update March 3, 2023, EPA Holds Third and Final TSCA Engineering Initiative Webinar. Many state agencies have also adopted the principle prohibitions of Title VIII, and with its 1988 amendments, the law has been strengthened, broadened, and attorney's fee provisions have permitted the private bar to play a primary role in its enforcement. 2011) (facially race neutral plan that involved assignment of students based on where they live did not trigger strict scrutiny). 2011) (looking to Title VII jurisprudence to analyze Title VI claims). For example, the Supreme Court has held that intentional racial segregation is a harm in and of itself. 2010)(Fair Housing Act case applying the Arlington Heights factors); Hallmark Developers, Inc. v. Fulton Cty., 466 F.3d 1276, 1283-84 (11th Cir. v. Seattle Sch. Although statistical evidence is usually used to establish a pattern or practice of intentional discrimination, it is not required to establish wide-spread or systemic discrimination. In some cases, people of color are outright denied a lease or mortgage because of their skin color, while in others, they are steered towards specific neighborhoods known for high crime rates, poorer access to schools, or other negative characteristics. In addition, impact evidence most often involves the presentation of statistical evidence. [6] Vill. Webadding water to reduce alcohol in wine. The Supreme Court has cautioned that the four McDonnell-Douglas elements are not an inflexible formulation. Teamsters, 431 U.S. at 358. The National Law Review is not a law firm nor is www.NatLawReview.com intended to be a referral service for attorneys and/or other professionals. These factors are non-exhaustive. Pac. PAVALCO TRADING nace con la misin de proporcionar soluciones prcticas y automticas para la venta de alimentos, bebidas, insumos y otros productos en punto de venta, utilizando sistemas y equipos de ltima tecnologa poniendo a su alcance una lnea muy amplia deMquinas Expendedoras (Vending Machines),Sistemas y Accesorios para Dispensar Cerveza de Barril (Draft Beer)as comoMaquinas para Bebidas Calientes (OCS/Horeca), enlazando todos nuestros productos con sistemas de pago electrnicos y software de auditora electrnica en punto de venta que permiten poder tener en la palma de su mano el control total de su negocio. By way of illustration, in some instances police departments have used race or national origin to direct law enforcement activities, and have attempted to justify their conduct by noting that specific individuals from that race or national origin group engaged in illegal activity. Waterhouse v. Hopkins, 490 U.S. 228, 277 (1989) (OConnor, J., By way of illustration, in Wilson v. Susquehanna Township Police Dept, 55 F.3d 126 (3d Cir. The most obvious form of religion-based discrimination is when a landlord informs prospective tenants that a specific apartment is unavailable because the landlord does not want to rent to people of a particular religion. [13] Similary, an agency may be able to use impact evidence under the deliberate indifference framework, originally developed to analyze hostile environment harassment claims, to show that the recipient knew a federally protected right was substantially likely to be violated and failed to act despite that knowledge. Id. And the Sheehan court explained why: because such a requirement would cripple enforcement of the discrimination laws. Sheehan, 173 F.3d at 1044. In these, unequally. [Further,] direct evidence of an, strategic site selection of new schools, and, Once a compelling interest is established, a, We have learned from experience that it is, 489 U.S. at 635 (Marshall, J. dissenting), and is not extensively discussed here. Direct evidence of discriminatory intent is evidence that, if believed, proves the fact [of discriminatory intent] without inference or presumption. Coghlan v. Am. Direct evidence often involves a statement from a decision-maker that expresses a discriminatory motive. Making assumptions about someone's abilities or character based on their ethnicity and basing a housing decision on that is also an example of national origin discrimination. "You can't treat people like that, you have to respect them and learn the laws. (808-586-8844). 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