Fair Housing Act Complaint - Connecticut

CONNECTICUT FAIR HOUSING ACT COMPLAINT

1. CAPTION

SUPERIOR COURT OF CONNECTICUT

JUDICIAL DISTRICT OF [____________________]

DOCKET NO. [____________________]

RETURN DATE: [DATE ON ACCOMPANYING JD-CV-1 SUMMONS]

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

1. Violation of Conn. Gen. Stat. § 46a-64c (Discriminatory Housing Practices);
2. Violation of the federal Fair Housing Act (42 U.S.C. §§ 3604, 3617); and
3. Failure to Provide Reasonable Accommodation / Modification (Conn. Gen. Stat. § 46a-64c; 42 U.S.C. § 3604(f)).

DEMAND FOR JURY TRIAL

Plaintiff alleges as follows:

2. PARTIES

2.1. Plaintiff. Plaintiff [PLAINTIFF NAME] ("Plaintiff") is, and at all relevant times was, a resident of [CITY, COUNTY], Connecticut, and an "aggrieved person" within the meaning of Conn. Gen. Stat. § 46a-51.

2.2. Defendant owner/landlord. Defendant [DEFENDANT] ("Defendant") is, and at all relevant times was, a [corporation / limited liability company / individual] that owns, operates, manages, or controls the dwelling at issue and is a "person" within the meaning of Conn. Gen. Stat. § 46a-51.

2.3. Individual Defendant. Defendant [INDIVIDUAL NAME] is, and at all relevant times was, a [manager / leasing agent / owner / employee] of Defendant acting within the course and scope of that agency, and is sued individually for his/her own discriminatory acts.

2.4. Subject property. The dwelling at issue is located at [PROPERTY ADDRESS] (the "Property") and is a "dwelling" within the meaning of Conn. Gen. Stat. § 46a-64b(2).

3. JURISDICTION AND VENUE

3.1. This Court has jurisdiction under Conn. Gen. Stat. § 51-164s and [☐ § 46a-98a, for a direct housing-discrimination action / ☐ § 46a-100, following a CHRO release of jurisdiction].

3.2. This Court has concurrent jurisdiction over the federal claims under 42 U.S.C. § 3613(a).

3.3. Venue is proper in the Judicial District of [____________________] under § 51-345 and, if proceeding after a CHRO release, § 46a-100, because [VENUE FACTS].

3.4. State claim route and timeliness (select one). ☐ Plaintiff brings a direct housing action under § 46a-98a within one year of the alleged discriminatory practice on [DATE]; the CHRO has neither obtained a conciliation agreement nor commenced a hearing concerning that practice. ☐ Plaintiff filed a CHRO complaint on [DATE], CHRO No. [__________], received a release of jurisdiction on [DATE], and brings this § 46a-100 action within 90 days after receipt of that release under § 46a-101(e) and within two years of filing the CHRO complaint under § 46a-102. The federal Count is filed within two (2) years of the discriminatory act under 42 U.S.C. § 3613(a).

4. FACTUAL ALLEGATIONS

4.1. Plaintiff is a member of one or more classes protected by Conn. Gen. Stat. § 46a-64c, which prohibits discriminatory housing practices because of race, creed, color, national origin, ancestry, sex, gender identity or expression, marital status, age, lawful source of income, familial status, status as a veteran, learning disability, physical or mental disability, status as a victim of domestic violence, and sexual orientation (the last under Conn. Gen. Stat. § 46a-81e).

4.2. On or about [DATE], Plaintiff [applied to rent / sought to purchase / resided at / inquired about] the Property.

4.3. Plaintiff is a member of the following protected class(es): [IDENTIFY — e.g., lawful source of income (Section 8/RAP/Housing Choice Voucher), disability (________), sexual orientation, gender identity or expression, race (________), familial status, status as a veteran, victim of domestic violence].

4.4. Defendant engaged in one or more of the following discriminatory housing practices (Conn. Gen. Stat. § 46a-64c(a)):

☐ Refusal to sell or rent after a bona fide offer, or refusal to negotiate (§ 46a-64c(a)(1))
☐ Discrimination in the terms, conditions, or privileges of sale or rental, or in services or facilities (§ 46a-64c(a)(2))
☐ Discriminatory notice, statement, or advertisement indicating a preference or limitation (§ 46a-64c(a)(3))
☐ Misrepresenting that a dwelling is unavailable when it is in fact available (§ 46a-64c(a)(4)(A))
☐ Steering / restricting buyer or renter choices based on protected class (§ 46a-64c(a)(4)(B))
☐ Refusal to make a reasonable accommodation in rules, policies, practices, or services (disability)
☐ Refusal to permit a reasonable modification of the premises (disability)
☐ Harassment or creation of a hostile housing environment
☐ Retaliation, coercion, intimidation, or interference for exercising fair-housing rights
☐ Lawful-source-of-income discrimination — refusing a tenant because of Section 8/RAP or other lawful subsidy
☐ Other: [DESCRIBE]

4.5. Specifically, the following occurred:

• [SPECIFIC INCIDENT 1 — date, actor, what was said/done, witnesses];
• [SPECIFIC INCIDENT 2];
• [SPECIFIC INCIDENT 3].

4.6. [Comparator evidence: Similarly situated applicants or tenants outside Plaintiff's protected class were treated more favorably, including [DESCRIBE].]

4.7. [Disability allegations, if applicable:] Plaintiff has a physical or mental disability within the meaning of Conn. Gen. Stat. § 46a-51, specifically [DESCRIBE]. On or about [DATE], Plaintiff requested the following reasonable accommodation/modification: [DESCRIBE — e.g., assistance animal in a "no pets" building, accessible parking, grab bars]. Defendant [denied the request / failed to respond / imposed unreasonable conditions].

4.8. As a direct and proximate result of Defendant's conduct, Plaintiff suffered the damages described below, including out-of-pocket losses, loss of housing opportunity, and emotional distress.

5. COUNT I — CONNECTICUT DISCRIMINATORY HOUSING PRACTICES (Conn. Gen. Stat. § 46a-64c)

5.1. Plaintiff incorporates the preceding paragraphs.

5.2. Defendant's conduct constitutes one or more discriminatory housing practices prohibited by Conn. Gen. Stat. § 46a-64c because of Plaintiff's [PROTECTED CLASS].

5.3. Defendant acted intentionally and/or its facially neutral policy had an unjustified discriminatory effect.

5.4. Plaintiff seeks actual damages, available punitive damages, injunctive relief, and reasonable attorney fees and costs under the applicable state civil-action route. Civil penalties under § 46a-89(b)(2)(D) are payable to the state in a commission petition and are not requested here.

6. COUNT II — FEDERAL FAIR HOUSING ACT (42 U.S.C. §§ 3604, 3617)

6.1. Plaintiff incorporates the preceding paragraphs.

6.2. Defendant's conduct violated 42 U.S.C. § 3604 by refusing to rent or sell, by making housing unavailable, and/or by discriminating in the terms, conditions, or privileges of housing because of Plaintiff's [race / color / religion / sex / familial status / national origin / disability].

6.3. Defendant further violated 42 U.S.C. § 3617 by coercing, intimidating, threatening, interfering with, or retaliating against Plaintiff for exercising rights protected by the federal Fair Housing Act.

6.4. This Count is timely under 42 U.S.C. § 3613(a). If a discriminatory housing practice is found, the court may award actual and punitive damages and appropriate injunctive or other relief under 42 U.S.C. § 3613(c)(1); the court may, in its discretion, allow the prevailing party reasonable attorney fees and costs under § 3613(c)(2).

7. COUNT III — REASONABLE ACCOMMODATION / MODIFICATION (DISABILITY)

7.1. Plaintiff incorporates the preceding paragraphs.

7.2. Plaintiff is a person with a physical or mental disability under Conn. Gen. Stat. § 46a-51 and 42 U.S.C. § 3602(h).

7.3. Plaintiff requested a reasonable accommodation in rules, policies, practices, or services and/or a reasonable modification of the premises necessary to afford Plaintiff equal opportunity to use and enjoy the dwelling.

7.4. The requested accommodation/modification was reasonable and necessary, and Defendant refused it in violation of Conn. Gen. Stat. § 46a-64c and 42 U.S.C. § 3604(f)(3)(A)-(B).

7.5. Plaintiff requests actual damages, any available punitive damages, appropriate injunctive relief, and fees and costs to the extent authorized for this count.

8. DAMAGES

8.1. Actual/compensatory damages: out-of-pocket losses, higher rent or relocation costs, lost housing opportunity, and other pecuniary harm, in amounts to be proven at trial.

8.2. Emotional distress damages: humiliation, embarrassment, anxiety, and loss of dignity.

8.3. Punitive damages: Conn. Gen. Stat. § 46a-89(b)(2)(C), as incorporated by § 46a-98a for a direct state housing action, authorizes an award to the complainant of up to $50,000; § 46a-104 governs relief after a CHRO release; and 42 U.S.C. § 3613(c)(1) authorizes punitive damages under the federal FHA.

8.4. Civil penalties: § 46a-89(b)(2)(D) makes these payable to the state in a commission petition; Plaintiff does not demand them.

8.5. Attorney fees and costs: under Conn. Gen. Stat. §§ 46a-89, 46a-104 and 42 U.S.C. § 3613(c)(2).

8.6. Pre- and post-judgment interest as allowed by law.

9. DEMAND FOR RELIEF — START ON A SEPARATE PAGE

[INSERT PAGE BREAK BEFORE THIS DEMAND IN THE FILED COMPLAINT]

Because money damages are sought, select one amount category under Conn. Gen. Stat. § 52-91, exclusive of interest and costs: ☐ $15,000 or more; ☐ $2,500 or more but less than $15,000; ☐ less than $2,500.

WHEREFORE, Plaintiff respectfully prays for judgment against Defendants as supported by the pleaded claims, applicable law, and proof, as follows:

• A. For actual and compensatory damages according to proof;
• B. For emotional-distress damages;
• C. For punitive damages under Conn. Gen. Stat. § 46a-89(b)(2)(C), if proceeding under § 46a-98a, or § 46a-104, if proceeding after a CHRO release, and 42 U.S.C. § 3613(c)(1);
• D. For a declaration that Defendants' conduct violated Connecticut and federal fair-housing laws;
• E. For permanent injunctive relief, including an order to cease the discriminatory practices, to provide the requested accommodation/modification, and to adopt non-discriminatory policies and training;
• F. For reasonable attorney fees and costs under Conn. Gen. Stat. §§ 46a-89, 46a-104 and 42 U.S.C. § 3613(c);
• G. For pre- and post-judgment interest; and
• H. For such other and further relief as the Court deems just and proper.

10. DEMAND FOR JURY TRIAL

Plaintiff demands a jury trial on every issue triable by jury as of right under Conn. Gen. Stat. § 52-215.

11. VERIFICATION

I, [PLAINTIFF NAME], declare under penalty of false statement under the laws of the State of Connecticut that I am the Plaintiff in this action, that I have read the foregoing Complaint, and that the matters stated herein are true of my own knowledge, except as to matters stated on information and belief, and as to those I believe them to be true.

Executed on [__/__/____] at [CITY], Connecticut.

[____________________]

[PLAINTIFF NAME]

12. SIGNATURE AND SERVICE BLOCKS

Date: [__/__/____]

Respectfully submitted,

[LAW FIRM NAME]

By: [____________________]

[ATTORNEY NAME], Connecticut Juris No. [______]

Attorney for Plaintiff

[STREET ADDRESS]

[CITY, STATE ZIP]

Telephone: [__________]

Email: [__________]

13. SERVICE OF ORIGINAL PROCESS

Serve the issued JD-CV-1 summons together with this complaint through a state marshal or other officer authorized to serve process under Conn. Gen. Stat. §§ 52-50 and 52-54. The serving officer supplies the return of service. Practice Book § 10-12 governs papers filed after the original complaint; electronic filing of this complaint does not serve the defendant.

14. CONNECTICUT PRACTICE NOTES

• Enforcing agency. The Connecticut Commission on Human Rights and Opportunities (CHRO), through its Housing Discrimination Unit, investigates and adjudicates housing-discrimination complaints under Conn. Gen. Stat. § 46a-64c.
• Protected classes (broader than federal). Conn. Gen. Stat. § 46a-64c: race, creed, color, national origin, ancestry, sex, gender identity or expression, marital status, age, lawful source of income, familial status, status as a veteran, learning disability, and physical or mental disability, plus status as a victim of domestic violence and sexual orientation (§ 46a-81e). "Lawful source of income" includes Section 8/Housing Choice Vouchers and the state Rental Assistance Program (RAP).
• State civil routes. A person alleging a violation of § 46a-64c or § 46a-81e may sue directly under § 46a-98a within one year, subject to its bar after a CHRO conciliation agreement or commenced hearing. The separate § 46a-100 route follows a CHRO complaint and release of jurisdiction. For a CHRO filing concerning an act on or after October 1, 2021, § 46a-82(f)(2) allows 300 days; § 46a-82(f)(1) controls earlier acts.
• Limitations periods.
• State administrative complaint to CHRO for an alleged act on or after October 1, 2021: 300 days (§ 46a-82(f)(2)); check (f)(1) for an earlier act.
• Direct state housing action: one year under § 46a-98a, subject to its CHRO-stage restriction.
• State court after CHRO release under § 46a-100: 90 days after receipt of release under § 46a-101(e) and two years after filing the CHRO complaint under § 46a-102; calendar both limits.
• Federal: 1 year to file a HUD administrative complaint (42 U.S.C. § 3610(a)); 2 years for a private federal court action (42 U.S.C. § 3613(a)).
• Damages and penalties. A direct private action under § 46a-98a may request relief available under §§ 46a-86 and 46a-89; § 46a-89(b)(2)(C) caps that provision's punitive award at $50,000. Section 46a-104 governs relief in a § 46a-100 action after CHRO release. Section 46a-89(b)(2)(D) makes civil penalties payable to the state in a commission petition, so omit them from a private plaintiff's prayer.
• Owner-occupied exemptions. Section 46a-64c(b)(1) generally excludes a rented room in the owner's occupied single-family dwelling or one unit in a two-family dwelling when the owner occupies the other. Section 46a-64c(b)(4) separately excludes some owner-occupied buildings of no more than four families from the familial-status prohibition. The former owner-occupied exemption in the sexual-orientation provision, § 46a-81e, was deleted by P.A. 23-207; do not apply § 46a-64c's exemptions automatically to a separate § 46a-81e claim.
• Filing process. Prepare the JD-CV-1 civil summons with its return date and serve it with the complaint under Practice Book § 8-1. Put the demand for relief on a separate page and select the § 52-91 monetary category under Practice Book § 10-20.
• Removal exposure. The federal count creates federal-question jurisdiction permitting removal under 28 U.S.C. § 1441.

15. SOURCES AND REFERENCES

• Conn. Gen. Stat. § 46a-64c (2026 supplement; discriminatory housing practices and exemptions) — https://www.cga.ct.gov/2026/sup/chap_814c.htm#sec_46a-64c
• Conn. Gen. Stat. Chapter 814c (Human Rights and Opportunities; §§ 46a-81e, 46a-89, 46a-98a, 46a-100–102, 46a-104) — https://www.cga.ct.gov/current/pub/chap_814c.htm
• Conn. Gen. Stat. § 46a-82 (2026 supplement; CHRO complaint filing period) — https://www.cga.ct.gov/2026/sup/chap_814c.htm#sec_46a-82
• Conn. Gen. Stat. § 52-91 (complaint demand) — https://www.cga.ct.gov/current/pub/chap_898.htm#sec_52-91
• Connecticut Practice Book (2026), §§ 8-1, 10-20 — https://www.jud.ct.gov/Publications/PracticeBook/PB.pdf
• CHRO — Fair Housing complaint process — https://portal.ct.gov/CHRO/Complaint-Process/Fair-Housing/What-happens-after-I-file-a-complaint
• GLAD — Housing Discrimination in Connecticut (sexual orientation / gender identity) — https://www.gladlaw.org/issues/housing-discrimination-connecticut/
• 42 U.S.C. § 3604 (federal FHA), § 3613 (private action), § 3617 (interference) — https://www.justice.gov/crt/fair-housing-act-2
• Texas Dep't of Housing & Community Affairs v. Inclusive Communities Project, Inc., 576 U.S. 519 (2015) (disparate impact under FHA)
• HUD/DOJ Joint Statement on Reasonable Accommodations (2004); Reasonable Modifications (2008)

Disclaimer: This template is provided for informational purposes only and does not constitute legal advice. An attorney licensed in Connecticut must review and customize this document before filing. Verify all statutory citations and court rules before use.