UNITED STATES DISTRICT COURT
DISTRICT OF IDAHO
UNITED STATES OF AMERICA,
Plaintiff,
v.
CIV 97-0538-S-BLW
CHARLES (a/k/a "Jerry") HARLAN,
MARLENE HARLAN & GOLDEN GATE
MOBILE HOME PARK,
Defendants.
______________________________
AMENDED CIVIL RIGHTS COMPLAINT
The United States of America alleges:
1. This action is brought by the United States to enforce the
provisions of Title VIII of the Civil Rights Act of 1968 (the Fair
Housing Act), as amended by the Fair Housing Amendments Act of
1988, 42 U.S.C. §§ 3601 et seq. It is brought on behalf of Glenda
Stone, Donald Mello, Frank Garcia, and David and Lisa Fernandez,
pursuant to Section 812(o) of the Fair Housing Act ("the Act"), as
amended, 42 U.S.C. § 3612(o), as well as pursuant to Section
814(a) of the Act, 42 U.S.C. § 3614(a).
2. This Court has jurisdiction over this action under 28 U.S.C.
1345 and 42 U.S.C. §§ 3612(o) & 3614(a).
3. Defendants Charles Harlan and Marlene Harlan are residents of
Boise, Idaho. At all relevant times, defendants Charles Harlan and
Marlene Harlan were joint owners of the Golden Gate Mobile Home
Park (the "Park"), located at 610 Kearney Street, in Caldwell,
Idaho.
4. The mobile homes, and spaces for mobile homes, in the Golden Gate
Mobile Home Park are dwellings within the meaning of 42 U.S.C.
3602(b).
5. Glenda Stone is a female of Mexican national origin who resides in
Nampa, Idaho. Donald Mello is an Anglo male who resides in
Council, Idaho. Frank Garcia is a male of Mexican national origin
who resides in Caldwell, Idaho. David Fernandez is a male of
Mexican national origin who resides in Wilder, Idaho. Lisa
Fernandez is an Anglo female who is married to David Fernandez and
resides with him in Wilder, Idaho.
6. In January, 1997, Donald Mello decided to sell his mobile home in
the Golden Gate Mobile Home Park, where he rented a space. In
SNIPPETS:
UNITED STATES DISTRICT COURT
MARLENE HARLAN & GOLDEN GATE MOBILE HOME PARK,
AMENDED CIVIL RIGHTS COMPLAINT
This action is brought by the United States to enforce the provisions of Title VIII of the
It is brought on behalf of Glenda Stone, Donald Mello, Frank Garcia, and David and Lisa
Defendants Charles Harlan and Marlene Harlan are residents of Boise, Idaho.
defendants Charles Harlan and Marlene Harlan were joint owners of the Golden Gate Mobile Home
Park, located at 610 Kearney Street, in Caldwell, Idaho.
Glenda Stone is a female of Mexican national origin who resides in Nampa,
Donald Mello is an Anglo male who resides in Council,
Frank Garcia is a male of Mexican national origin who resides in Caldwell,
David Fernandez is a male of Mexican national origin who resides in Wilder,
Lisa Fernandez is an Anglo female who is married to David Fernandez and resides with him in
During the course of these discussions, Mr. Harlan made statements indicating a preference
Stone alleged that in February, 1997, defendant Charles Harlan engaged in unlawful
Based on information gathered in the investigation, the Secretary, pursuant to 42 U.S.C. §
Accordingly, on September 29, 1997, the Secretary issued a Charge of Discrimination pursuant
refused to sell or rent, or to negotiate for the sale or rental of, or otherwise made
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