UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF IDAHO
UNITED STATES OF AMERICA,
Plaintiff,
v.
HALLMARK HOMES, INC.,
ARCHITECTS WEST, P.A., and
KEVIN W. JESTER,
Defendants.
__________________________________
COMPLAINT
DEMAND FOR JURY TRIAL
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 the
Intermountain Fair Housing Council 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 28 U.S.C. § 3614(a).
3. Venue is proper in that the claims alleged herein arose in the
District of Idaho.
4. The Creekside Meadows Apartments ("Creekside Meadows") are
multifamily dwellings located in Coeur d'Alene, Idaho, in the
District of Idaho.
5. Creekside Meadows were designed and constructed for first
occupancy after March 13, 1991. Each apartment at the Creekside
Meadows is a dwelling within the meaning of 42 U.S.C. § 3602(b).
6. Creekside Meadows consist of seven buildings located at 2200-2366
North 15^th Street in Coeur d'Alene. Each building consists of
four dwelling units, with two single story dwelling units and two
multistory units. Therefore, there are a total of twenty-eight
dwelling units, fourteen multistory units and fourteen ground
floor units.
7. Each of the fourteen ground units at Creekside Meadows is a
"covered multifamily dwelling" within the meaning of 42 U.S.C.
3604(f)(7)(A) and is subject to the design and construction
SNIPPETS:
UNITED STATES DISTRICT COURT
The United States of America alleges:
This action is brought by the United States to enforce the provisions of Title VIII of the
It is brought on behalf of the Intermountain Fair Housing Council pursuant to Section 812of
Venue is proper in that the claims alleged herein arose in the District of Idaho.
The Creekside Meadows Apartments are multifamily dwellings located in Coeur d'Alene, Idaho,
Each building consists of four dwelling units, with two single story dwelling units and two
Therefore, there are a total of twenty-eight dwelling units, fourteen multistory units and
Each of the fourteen ground units at Creekside Meadows is a "covered multifamily dwelling"
Defendant Architects West has its principal place of business in Coeur d'Alene,
Architects West designed the dwelling units and common areas at Creekside Meadows.
The Intermountain Fair Housing Council, formerly known as the Idaho Fair Housing Council, is
On or about March 24, 1999, the Intermountain Fair Housing Council filed a timely complaint
In its complaint, the Intermountain Fair Housing Council alleged that its purpose of
The Intermountain Fair Housing Council diverted resources from its other activities to
Based on information gathered in the investigation, the Secretary, pursuant to 42 U.S.C. §
doorways to the bedrooms and the master bathrooms within the fourteen covered units are not
lls lack reinforcements to allow later installation of grab bars; and the bathrooms are not usable
The discriminatory actions of Defendants were intentional, willful and taken in disregard for
Plaintiff re-alleges and herein incorporates by reference the allegations set forth in
Interm United States Attorney
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