UNITED STATES DISTRICT COURT
DISTRICT OF IDAHO
UNITED STATES OF AMERICA,
Plaintiff,
v.
CHERRYWOOD ASSOCIATES, LP
GERALD C. BAUMAN, THOMAS E.
DILLON, TOMLINSON & ASSOCIATES,
INC., and JULIE WINN,
Defendants.
_____________________________________
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. §§ 3601-3619. It is brought on behalf of Spencer
D. and Toni Jones, and their minor children, Darian, Chelsea, and
Brittanie Jones, and the Idaho Fair Housing Council pursuant to
Section 812(o) of the Fair Housing Act ("the Act"), as amended, 42
U.S.C. § 3612(o).
2. This Court has jurisdiction over this action under 28 U.S.C.
1345 and 42 U.S.C. §§ 3612(o).
3. Defendant Cherrywood Associates, LP, is a limited liability
company and is located in the District of Idaho. At all relevant
times, Cherrywood Associates, LP was the owner of the Saturn
Village Apartments located at 740 Saturn Drive, Idaho Falls, Idaho
83402 in the District of Idaho.
4. The Saturn Village Apartment complex receives Section 8
project-based funding from the U.S. Department of Housing and
Urban Development through the Idaho Housing Finance Agency. It is
one of the few affordable housing complexes for low income
families in the area.
5. At all relevant times, Defendants Gerald C. Bauman and Thomas E.
Dillon were the general partners of Cherrywood Associates, LP.
Defendants Bauman and Dillon reside and do business in the
District of Idaho.
6. At all relevant times, Defendant Tomlinson & Associates, Inc. was
the management firm for Saturn Village Apartments. The corporation
is licensed to do business in the State of Idaho and is located at
242 North 8^th Street, Boise, Idaho 83701 in the District of
SNIPPETS:
UNITED STATES DISTRICT COURT
DISTRICT OF IDAHO
INC., and JULIE WINN, Defendants.
This action is brought by the United States to enforce the provisions of Title VIII of the
It is brought on behalf of Spencer D. and Toni Jones, and their minor children, Darian,
Defendant Cherrywood Associates, LP, is a limited liability company and is located in the
At all relevant times, Cherrywood Associates, LP was the owner of the Saturn Village
The Saturn Village Apartment complex receives Section 8 project-based funding from the U.S.
At all relevant times, Defendant Tomlinson & Associates, Inc. was the management firm for
At all relevant times, Defendant Julie Winn was the on-site property manager of Saturn
Spencer D. and Toni Jones are husband and wife, the parents of Darian, Chelsea and Brittanie
The Idaho Fair Housing Council is a nonprofit organization that promotes fair housing
At all times relevant to the complaint, Defendants have stated, adopted, and enforced an
This policy has had the effect of excluding families with children, including the Jones
Defendant Winn declined to permit Jones to apply for an apartment, stating that because the
In an attempt to remedy problems caused by Defendants' discriminatory housing policies,
The Idaho Fair Housing Council diverted resources from its usual educational and enforcement
On or about October 8, 1998, Spencer and Toni Jones filed a timely complaint with the United
Accordingly, on September 20, 2000, the Secretary issued a Charge of Discrimination pursuant
Following this Notice of Election, the Secretary of Housing and Urban Development authorized
refused to rent, or to negotiate for the rental of, or otherwise made unavailable or denied,
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