Fair Housing Act Complaint Template

United States District Court for the [District] of [State]

[Plaintiff Name(s)],
Plaintiff(s),

v.
[Defendant Name(s)],
Defendant(s).

Case No. [To be assigned]

COMPLAINT

Plaintiff(s) allege:

I. Jurisdiction and Venue

1. This action arises under the Fair Housing Act, 42 U.S.C. §§ 3601-3619.
2. Jurisdiction is proper pursuant to 28 U.S.C. §§ 1331 and 1343.
3. Venue is proper under 28 U.S.C. § 1391 because the property and events at issue are located in this District.

II. Parties

4. Plaintiff [Name] is a [protected class status] residing in [City, State].
5. Defendant [Name] is the owner/manager/agent of residential property located at [Address].
6. [Additional defendants including management companies, real estate agents, HOAs, etc.]

III. Factual Background

7. On or about [Date(s)], Plaintiff sought to [rent/purchase] housing at [Property].
8. Defendant engaged in discriminatory housing practices by [describe actions: refusing to rent, steering, imposing different terms, harassment, failure to accommodate].
9. Plaintiff requested [reasonable accommodation/modification] on [Date], which Defendant denied or failed to respond to.
10. Defendant’s actions were based on Plaintiff’s [protected characteristic], violating the Fair Housing Act.
11. As a result, Plaintiff suffered damages including emotional distress, out-of-pocket expenses, and loss of housing opportunity.

IV. Causes of Action

Count I – Discrimination under 42 U.S.C. § 3604

12. Defendant’s conduct constitutes discrimination in the sale or rental of housing because of [protected class].

Count II – Failure to Provide Reasonable Accommodation (if applicable)

13. Defendant refused to make reasonable accommodations necessary for Plaintiff to use and enjoy the dwelling, in violation of 42 U.S.C. § 3604(f)(3).

Count III – Retaliation (if applicable)

14. Defendant retaliated against Plaintiff for exercising rights under the Fair Housing Act, in violation of 42 U.S.C. § 3617.

V. Damages

15. Plaintiff seeks compensatory damages for emotional distress, economic losses, and other injuries.
16. Plaintiff seeks punitive damages due to Defendant’s willful and malicious conduct.
17. Plaintiff seeks attorneys’ fees and costs pursuant to 42 U.S.C. § 3613(c).

VI. Prayer for Relief

WHEREFORE, Plaintiff requests that the Court:
- Declare Defendant’s conduct unlawful;
- Award compensatory and punitive damages;
- Grant injunctive relief requiring Defendant to cease discriminatory practices and implement fair housing policies and training;
- Award attorneys’ fees and costs; and
- Grant such other relief as the Court deems just and proper.

VII. Jury Demand

18. Plaintiff demands a jury trial on all issues triable by jury.

Respectfully submitted,

[Law Firm Name]

By: ________
[Attorney Name] (Bar No. [Number])
[Address]
[Phone]
[Email]

Date: [Date]