Fair Housing Act Complaint - District of Columbia

DISTRICT OF COLUMBIA FAIR HOUSING COMPLAINT (D.C. HUMAN RIGHTS ACT)

TABLE OF CONTENTS

1. Caption
2. Parties
3. Jurisdiction and Venue
4. Factual Allegations
5. Count I — D.C. Human Rights Act (D.C. Code § 2-1402.21, § 2-1402.61)
6. Count II — Federal Fair Housing Act (42 U.S.C. § 3604, § 3617)
7. Count III — Reasonable Accommodation / Modification (Disability)
8. Damages
9. Prayer for Relief
10. Demand for Jury Trial
11. Verification
12. Signature and Service
13. Certificate of Service
14. District of Columbia Practice Notes
15. Sources and References

1. CAPTION

SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

CIVIL DIVISION

Case No. [____]

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF — HOUSING DISCRIMINATION

1. Violation of the D.C. Human Rights Act (D.C. Code § 2-1402.21);
2. Violation of the Federal Fair Housing Act (42 U.S.C. § 3604, § 3617); and
3. Failure to Make Reasonable Accommodation / Permit Reasonable Modification.

DEMAND FOR JURY TRIAL

Plaintiff, by and through undersigned counsel, alleges as follows:

2. PARTIES

2.1. Plaintiff. Plaintiff [PLAINTIFF NAME] ("Plaintiff") is, and at all relevant times has been, a resident of the District of Columbia. Plaintiff is a person aggrieved by an unlawful discriminatory practice within the meaning of D.C. Code § 2-1403.16 and an "aggrieved person" under 42 U.S.C. § 3602(i), and possesses one or more protected traits under the D.C. Human Rights Act, specifically: [PROTECTED TRAIT(S)].

2.2. Defendant Owner / Housing Provider. Defendant [DEFENDANT NAME] ("[SHORT NAME]") is, and at all relevant times has been, a [corporation / limited liability company / partnership / individual] that owns, operates, manages, and/or leases the real property at issue and engaged in the transaction in real property described below.

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

2.4. Additional Defendants. Defendant [BROKER / SALESPERSON / LENDER] is named with respect to [brokerage services / financing / real estate-related transaction] under D.C. Code § 2-1402.21(a)(3), (a)(7), and § 2-1402.23.

2.5. The Subject Real Property. The housing at issue is located at [PROPERTY ADDRESS], Washington, D.C. ("the Property").

3. JURISDICTION AND VENUE

3.1. Subject-matter jurisdiction. This Court has jurisdiction over the D.C. Human Rights Act claims pursuant to D.C. Code § 2-1403.16, which authorizes any person claiming to be aggrieved by an unlawful discriminatory practice to file a private cause of action in a court of competent jurisdiction for damages and other appropriate relief, and pursuant to D.C. Code § 11-921.

3.2. Federal claims. This Court has concurrent jurisdiction over the parallel federal Fair Housing Act claims under 42 U.S.C. § 3613.

3.3. Venue. Venue is proper in the District of Columbia because the discriminatory practice occurred in the District and the Property is located in the District.

3.4. Administrative status / election of remedies. Plaintiff [has not filed an administrative complaint with the Office of Human Rights and proceeds directly to court / filed a complaint with the Office of Human Rights and properly withdrew it and elected to proceed in court / received a notice of right to file a civil action]. For residential real estate complaints in which the Office of Human Rights has made a probable cause finding, the election-of-remedies procedure of D.C. Code § 2-1403.05 applies.

4. FACTUAL ALLEGATIONS

4.1. On or about [DATE], Plaintiff [applied to rent / sought to purchase / was a tenant of / sought financing for] the Property.

4.2. Plaintiff possesses the following protected trait(s) under the D.C. Human Rights Act: [IDENTIFY — e.g., race, color, religion, national origin, sex, age, marital status, personal appearance, sexual orientation, gender identity or expression, familial status, family responsibilities, disability, matriculation, political affiliation, source of income, sealed eviction record, status as a victim of an intrafamily offense, place of residence or business, or homeless status].

4.3. At all relevant times Plaintiff was [qualified to rent / qualified to purchase / a tenant in good standing] and met Defendants' legitimate, non-discriminatory requirements.

4.4. Unlawful discriminatory practice. Defendants engaged in one or more of the following acts in a transaction in real property, wholly or partially for a discriminatory reason based on Plaintiff's protected trait (check all that apply):

☐ Refusal or failure to initiate or conduct a transaction in real property, or requiring different terms (D.C. Code § 2-1402.21(a)(1); 42 U.S.C. § 3604(a)–(b))
☐ Including a discriminatory clause, condition, or restriction in the terms of a transaction (D.C. Code § 2-1402.21(a)(2))
☐ Discriminatory financing, lending, appraisal, or refusal to make funds available (D.C. Code § 2-1402.21(a)(3), (a)(6); 42 U.S.C. § 3605)
☐ Refusal or restriction of facilities, services, repairs, or improvements for a tenant (D.C. Code § 2-1402.21(a)(4))
☐ Discriminatory notice, statement, or advertisement (D.C. Code § 2-1402.21(a)(5); 42 U.S.C. § 3604(c))
☐ Steering or blockbusting (D.C. Code § 2-1402.22; 42 U.S.C. § 3604(e))
☐ False representation that real property is unavailable (D.C. Code § 2-1402.21(a)(1); 42 U.S.C. § 3604(d))
☐ Refusal to make a reasonable accommodation or permit a reasonable modification for disability (D.C. Code § 2-1402.21; 42 U.S.C. § 3604(f)(3))
☐ Harassment or creation of a hostile housing environment
☐ Coercion, intimidation, interference, or retaliation (D.C. Code § 2-1402.61; 42 U.S.C. § 3617)
☐ Discrimination based on source of income, personal appearance, family responsibilities, matriculation, political affiliation, place of residence or business, homeless status, sealed eviction record, or status as a victim of an intrafamily offense (District-specific protected traits; D.C. Code § 2-1402.21)

4.5. Specifically, Defendants engaged in the following conduct:

• [SPECIFIC INCIDENT 1 — date, decision-maker, conduct, words spoken, witnesses];
• [SPECIFIC INCIDENT 2];
• [SPECIFIC INCIDENT 3].

4.6. [Comparator evidence, if available: Similarly situated applicants or tenants without Plaintiff's protected trait(s) were treated more favorably, including [DESCRIBE].]

4.7. [Where applicable — disability:] Plaintiff has a disability within the meaning of D.C. Code § 2-1401.02 and 42 U.S.C. § 3602(h), namely [DESCRIBE FUNCTIONAL LIMITATION]. On or about [DATE], Plaintiff requested [the reasonable accommodation / modification of: DESCRIBE], which was necessary to afford Plaintiff an equal opportunity to use and enjoy the Property. Defendants [denied the request / failed to respond / imposed unreasonable conditions / retaliated].

4.8. [Subterfuge:] To the extent Defendants assert a non-discriminatory reason, that reason would not have been asserted but for Plaintiff's protected trait, and is unlawful under D.C. Code § 2-1402.21(b).

4.9. As a direct and proximate result of Defendants' conduct, Plaintiff suffered the harm described in the Damages section below.

5. COUNT I — D.C. HUMAN RIGHTS ACT (D.C. Code § 2-1402.21, § 2-1402.61)

5.1. Plaintiff incorporates Paragraphs 2.1 through 4.9 as though fully set forth.

5.2. The D.C. Human Rights Act makes it an unlawful discriminatory practice to engage in the acts described in D.C. Code § 2-1402.21(a)–(b) in a transaction in real property, wholly or partially for a discriminatory reason based on the actual or perceived protected traits enumerated therein.

5.3. Defendants committed an unlawful discriminatory practice by engaging in the conduct alleged in Paragraph 4.4 because of, or on a pretext that would not have been asserted but for, Plaintiff's protected trait(s).

5.4. Defendants further coerced, threatened, retaliated against, or interfered with Plaintiff in the exercise of rights protected by the DCHRA, in violation of D.C. Code § 2-1402.61.

5.5. The DCHRA is among the broadest civil rights statutes in the nation, and its protected traits include source of income, personal appearance, family responsibilities, matriculation, political affiliation, place of residence or business, homeless status, sealed eviction record, and status as a victim of an intrafamily offense, in addition to the federally protected classes.

5.6. As a direct and proximate result, Plaintiff is entitled to compensatory damages, punitive damages, and other appropriate relief under D.C. Code § 2-1403.16, § 2-1403.07, and § 2-1403.13(a), plus reasonable attorneys' fees and costs.

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

6.1. Plaintiff incorporates Paragraphs 2.1 through 4.9 as though fully set forth.

6.2. The federal Fair Housing Act makes it unlawful to refuse to sell or rent, to discriminate in the terms or conditions of housing, to make discriminatory statements, or to otherwise make housing unavailable because of race, color, religion, sex, familial status, national origin, or disability. 42 U.S.C. § 3604.

6.3. Defendants' conduct alleged in Paragraph 4.4 constitutes discrimination in violation of 42 U.S.C. § 3604(a)–(d) and, where lending or real estate-related transactions are at issue, 42 U.S.C. § 3605.

6.4. Defendants further coerced, intimidated, threatened, interfered with, or retaliated against Plaintiff in the exercise of FHA-protected rights, in violation of 42 U.S.C. § 3617.

6.5. Pursuant to 42 U.S.C. § 3613, Plaintiff is entitled to actual and punitive damages, injunctive relief, and reasonable attorneys' fees and costs. There is no federal cap on compensatory or punitive damages in a private FHA action.

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

7.1. Plaintiff incorporates Paragraphs 2.1 through 4.9 as though fully set forth.

7.2. Plaintiff is a person with a disability within the meaning of D.C. Code § 2-1401.02 and 42 U.S.C. § 3602(h).

7.3. It is unlawful discrimination to refuse to make reasonable accommodations in rules, policies, practices, or services, or to refuse to permit reasonable modifications, when necessary to afford a person with a disability an equal opportunity to use and enjoy a dwelling, under the DCHRA and 42 U.S.C. § 3604(f)(3).

7.4. Plaintiff requested the reasonable accommodation/modification described in Paragraph 4.7, which was necessary and reasonable, and Defendants unlawfully denied or failed to engage in the interactive process regarding that request.

7.5. As a direct and proximate result, Plaintiff has suffered damages and is entitled to relief under D.C. Code § 2-1403.16 and 42 U.S.C. § 3613.

8. DAMAGES

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

8.2. Emotional distress damages: humiliation, embarrassment, mental anguish, anxiety, and loss of dignity arising from the discrimination.

8.3. Punitive damages: Defendants acted intentionally, willfully, and/or with reckless or malicious disregard for Plaintiff's protected rights, warranting punitive damages under the DCHRA and 42 U.S.C. § 3613(c).

8.4. Civil penalties: Available in administrative enforcement before the Commission on Human Rights and under the federal enforcement scheme against respondents found to have committed discriminatory practices.

8.5. Attorneys' fees and costs: Recoverable under the DCHRA (D.C. Code § 2-1403.13(a)(1)(E)) and 42 U.S.C. § 3613(c)(2).

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

9. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully prays for judgment against Defendants, jointly and severally, as follows:

• A. For actual and compensatory damages according to proof;
• B. For damages for emotional distress, humiliation, and loss of dignity;
• C. For punitive damages under the DCHRA and 42 U.S.C. § 3613(c);
• D. For a declaration that Defendants' conduct violated the D.C. Human Rights Act and the federal Fair Housing Act;
• E. For injunctive relief, including an order that Defendants cease the discriminatory practices, make the Property available to Plaintiff, grant the requested accommodation/modification, and adopt non-discriminatory policies and training;
• F. For reasonable attorneys' fees and costs under D.C. Code § 2-1403.13(a) and 42 U.S.C. § 3613(c)(2);
• G. For pre-judgment 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 hereby demands a trial by jury on all issues so triable as a matter of right.

11. VERIFICATION

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

Executed on [__/__/____] at Washington, D.C.

[________________________________]

[PLAINTIFF NAME]

12. SIGNATURE AND SERVICE

Date: [__/__/____]

Respectfully submitted,

[LAW FIRM NAME]

By: [________________________________]

[ATTORNEY NAME], D.C. Bar No. [____]

Counsel for Plaintiff

[STREET ADDRESS]

[CITY, STATE ZIP]

Telephone: [____]

Email: [____]

13. CERTIFICATE OF SERVICE

I hereby certify that on [__/__/____], I caused a true and correct copy of the foregoing COMPLAINT to be served on the following parties by [method — personal service / certified mail / CaseFileXpress electronic service per Super. Ct. Civ. R. 5]:

[SERVICE LIST WITH NAMES AND ADDRESSES]

[________________________________]

[NAME / TITLE]

14. DISTRICT OF COLUMBIA PRACTICE NOTES

• Enforcing agency. The D.C. Office of Human Rights (OHR) investigates housing-discrimination complaints; the D.C. Commission on Human Rights adjudicates after a probable cause finding.
• Administrative charge vs. direct court suit. A complainant may EITHER file an administrative complaint with OHR OR proceed directly to court under D.C. Code § 2-1403.16. Filing with OHR and maintaining a court action simultaneously is barred (election of remedies, § 2-1403.16(e)).
• Limitations periods (IMPORTANT — recently amended). The deadline to file an administrative complaint with OHR is ONE (1) YEAR after the unlawful discriminatory act (D.C. Code § 2-1403.04(a)). The deadline to file a private cause of action in court is TWO (2) YEARS after the unlawful act or its discovery (D.C. Code § 2-1403.16(b)) — increased from one year by the Fairness in Human Rights Administration Amendment Act of 2024, which OHR began enforcing on October 1, 2025. Timely filing with OHR tolls the court limitations period until OHR serves a notice of right to file a civil action.
• Residential real estate election of remedies. If OHR makes a probable cause finding in a residential real estate matter, the separate election-of-remedies procedure of D.C. Code § 2-1403.05 governs, and the election generally must be made within 20 days after service of the probable cause determination. Confirm the applicable procedure.
• District-specific protected traits. The DCHRA is among the broadest civil rights laws in the country. Housing-enforcement traits include race, color, religion, national origin, sex, age, marital status, personal appearance, sexual orientation, gender identity or expression, familial status, family responsibilities, disability, matriculation, political affiliation, source of income, sealed eviction record, status as a victim of an intrafamily offense, place of residence or business, and homeless status (D.C. Code § 2-1402.21). Source-of-income protection reaches Housing Choice (Section 8) vouchers and other lawful income.
• Remedies. Compensatory damages (no cap), punitive damages, declaratory and injunctive relief, civil penalties in administrative enforcement, and attorneys' fees and costs.
• Forum / removal. The DCHRA private action lies in the Superior Court of the District of Columbia. Adding the federal FHA counts permits removal to the U.S. District Court for the District of Columbia.
• Unsettled / verify: Confirm the current effective limitations text under the Fairness Act and the exact contours of the § 2-1403.05 residential real estate election-of-remedies procedure before filing.

15. SOURCES AND REFERENCES

• D.C. Human Rights Act, D.C. Code § 2-1401.01 et seq. — https://code.dccouncil.gov/us/dc/council/code/titles/2/chapters/14
• D.C. Code § 2-1402.21 (housing prohibitions) — https://code.dccouncil.gov/us/dc/council/code/sections/2-1402.21
• D.C. Code § 2-1403.16 (private cause of action) — https://code.dccouncil.gov/us/dc/council/code/sections/2-1403.16
• D.C. Code § 2-1403.04 (1-year OHR filing), § 2-1403.05 (residential real estate election of remedies)
• DC Office of Human Rights — Protected Traits — https://ohr.dc.gov/page/protected-traits
• DC OHR Fact Sheet 26-03 — Fairness in Human Rights Administration Amendment Act (Feb. 2026) — https://ohr.dc.gov/
• Federal Fair Housing Act, 42 U.S.C. § 3601 et seq. — https://www.justice.gov/crt/fair-housing-act-1
• 42 U.S.C. § 3604, § 3605, § 3613, § 3617
• 24 C.F.R. Part 100 (HUD Fair Housing regulations)
• Texas Dep't of Housing & Community Affairs v. Inclusive Communities Project, Inc., 576 U.S. 519 (2015) (disparate impact)

Disclaimer: This template is provided for informational purposes only and does not constitute legal advice. An attorney licensed in the District of Columbia must review and customize this document before filing. Laws, citations, and court rules change frequently; verify all authorities before use.