IN THE UNITED STATES DISTRICT COURT FOR
                         THE DISTRICT OF NEW JERSEY

   UNITED STATES OF AMERICA,
        Plaintiff,

   v.

                                                  C.A. No. 94CV1126 (JEI)

   CITY OF WILDWOOD, NEW JERSEY;
   DIANE TULLIE, City Inspector;
   and WILLIAM GANNON, City
   Inspector,
        Defendants.

   __________________________________

                                 COMPLAINT

   The United States of America alleges:

    1. This action is brought by the Attorney General on behalf of the
       United States to enforce Title VIII of the Civil Rights Act of
       1968, the Fair Housing Act, as amended by the 1988 Fair Housing
       Amendments Act, 42 U.S.C. §3601 et seq., pursuant to 42 U.S.C.
       §3614.
    2. This court has jurisdiction of this action pursuant to 42 U.S.C.
       §3614.
    3. Defendant City of Wildwood is a municipality located in the State
       of New Jersey within the District of New Jersey.
    4. Defendant Diane Tullie is a property maintenance inspector for the
       City of Wildwood. Defendant Tullie is, among other things,
       responsible for enforcing the City's Property Maintenance Code.
    5. Defendant William Gannon is an electrical inspector for the City
       of Wildwood. Defendant Gannon is, among other things, responsible
       for enforcing the City's Electrical Code.
    6. The City of Wildwood exercises authority over properties within
       its boundaries. The City has enacted and enforced health, safety
       and occupancy regulations, including the minimum occupancy
       provisions set forth in the Property Maintenance Code of the City
       of Wildwood.
    7. In 1990, the defendant City enacted an ordinance which limits the
       number of persons who may occupy a residential dwelling based on
       the size of the dwelling. Pursuant to the terms of Ordinance
       265-90, a dwelling unit to be occupied by 1, 2, or 3 persons must
       be at least 550 square feet in size; a dwelling unit to be
       occupied by 4 to 5 persons must be at least 800 square feet in

                     IN THE UNITED STATES DISTRICT FOR
                         THE DISTRICT OF NEW JERSEY

   UNITED STATES OF AMERICA,
        Plaintiff,

   v.

                                                  C.A. NO. 94CV1126 (JEI)

   CITY OF WILDWOOD, NEW JERSEY;
   DIANE TULLIE, City Inspector;
   and WILLIAM GANNON, City
   Inspector,
        Defendants.

                               CONSENT ORDER

   The United States commenced this action on March 4, 1994 alleging
   violations of the Fair Housing Act, 42 U.S.C. § 3614, as amended by
   the Fair Housing Amendments Act of 1988, 42 U.S.C. SS 3601, et seq.
   The Complaint alleges that the defendants City of Wildwood, New
   Jersey, Diane Tullie and William Gannon have engaged in a pattern or
   practice of discriminating on the basis of familial status and
   national origin against persons who seek to rent dwellings in the City
   of Wildwood. In particular, the Complaint alleges that the purpose and
   effect of minimum occupancy limitations enacted by the City in 1990
   has been to limit or preclude families with children, especially
   Hispanic families with children, from residing within the City of
   Wildwood. The Complaint seeks actual damages for all aggrieved
   persons, including persons as yet unidentified, punitive damages, and
   a civil penalty.

   The defendants admit that if this case were to proceed to trial, the
   United States would be able to establish the following, which would be
   consistent with a finding by the Court that a disparate impact on
   families with children, particularly Hispanic families with children,
   resulted from the enactment and enforcement of Wildwood's current
   square footage requirements, in violation of the amended Fair Housing
   Act, 42 U.S.C. § 3604:

    1. The City of Wildwood, New Jersey is a political subdivision
       established and operated as a municipal corporation under the laws
       of the State of New Jersey. Wildwood is located on the
       southeastern shore of the state. It is a seaside resort during the
       summer.
    2. At the time of the 1980 Census, the City of Wildwood had a total
       population of 4,902 persons, of whom 142 or 2.9 per cent were