Fair Housing Act Complaint - Wyoming

WYOMING FAIR HOUSING COMPLAINT (FEDERAL FAIR HOUSING ACT)

1. CAPTION

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF WYOMING

Civil Action No. [____________________]

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

1. Violation of the federal Fair Housing Act (42 U.S.C. §§ 3604, 3605, 3617);
2. Violation of 42 U.S.C. § 1982 (equal property rights) [where race-based];
3. Failure to Provide Reasonable Accommodation / Modification (42 U.S.C. § 3604(f)); and
4. Violation of the Wyoming Fair Housing Act (Wyo. Stat. Ann. § 40-26-101 et seq.). [OPTIONAL — see Practice Notes regarding the absence of a state enforcement agency]

JURY TRIAL DEMANDED

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], Wyoming, and an "aggrieved person" within the meaning of 42 U.S.C. § 3602(i).

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 within the meaning of 42 U.S.C. § 3602.

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 housing practices.

2.4. Doe Defendants. The true names and capacities of Defendants sued as Does 1 through 10 are presently unknown to Plaintiff, who will seek leave to amend when they are ascertained.

2.5. Subject property. The "dwelling" at issue, within the meaning of 42 U.S.C. § 3602(b), is located at [PROPERTY ADDRESS] (the "Property").

3. JURISDICTION AND VENUE

3.1. This Court has federal-question subject-matter jurisdiction under 28 U.S.C. §§ 1331 and 1343 and under 42 U.S.C. § 3613(a) over the federal Fair Housing Act and 42 U.S.C. § 1982 claims.

3.2. [If pleading the state count:] This Court has supplemental jurisdiction over the Wyoming Fair Housing Act claim under 28 U.S.C. § 1367(a) because it forms part of the same case or controversy.

3.3. [Concurrent state-court jurisdiction:] A Wyoming state court would have concurrent jurisdiction over the federal Fair Housing Act claims under 42 U.S.C. § 3613(a).

3.4. Venue is proper in this District under 28 U.S.C. § 1391(b) because the Property and the events giving rise to the claims are located in this District and Defendant resides or does business here.

3.5. Timeliness. This action is filed within two (2) years after the occurrence or the termination of the alleged discriminatory housing practice, as required by 42 U.S.C. § 3613(a)(1)(A), excluding any period during which an administrative proceeding before HUD was pending. [The 42 U.S.C. § 1982 claim is governed by Wyoming's residual personal-injury limitations period; confirm before filing.]

4. FACTUAL ALLEGATIONS

4.1. Plaintiff is a member of one or more classes protected by the federal Fair Housing Act, which prohibits housing discrimination because of race, color, religion, sex (including sexual orientation and gender identity), familial status, national origin, or disability (42 U.S.C. § 3604; 24 C.F.R. Part 100).

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., disability (________), race (________), familial status, national origin (________), sex/sexual orientation/gender identity, religion].

4.4. Defendant engaged in one or more of the following discriminatory housing practices:

☐ Refusal to sell or rent after a bona fide offer, or refusal to negotiate for sale or rental (42 U.S.C. § 3604(a))
☐ Discrimination in the terms, conditions, or privileges of sale or rental, or in services or facilities (42 U.S.C. § 3604(b))
☐ Discriminatory notice, statement, or advertisement indicating a preference, limitation, or discrimination (42 U.S.C. § 3604(c))
☐ Misrepresenting that a dwelling is unavailable when it is in fact available (42 U.S.C. § 3604(d))
☐ Blockbusting / inducing a transaction by neighborhood-composition representations (42 U.S.C. § 3604(e))
☐ Steering to or away from particular buildings, areas, or neighborhoods
☐ Refusal to permit a reasonable modification of the premises (disability) (42 U.S.C. § 3604(f)(3)(A))
☐ Refusal to make a reasonable accommodation in rules, policies, practices, or services (disability) (42 U.S.C. § 3604(f)(3)(B))
☐ Discrimination in a residential real estate-related transaction / financing (42 U.S.C. § 3605)
☐ Harassment or creation of a hostile housing environment
☐ Interference, coercion, or intimidation for exercising fair-housing rights; or retaliation (42 U.S.C. § 3617)
☐ Source-of-income or other practice actionable under an applicable local ordinance, if any (Wyoming has no statewide source-of-income protection)
☐ 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 disability ("handicap") within the meaning of 42 U.S.C. § 3602(h), specifically [DESCRIBE]. On or about [DATE], Plaintiff requested the following reasonable accommodation/modification: [DESCRIBE — e.g., assistance/service animal in a "no pets" building, accessible parking, grab bars]. Defendant [denied the request / failed to engage in the interactive process / 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 — FEDERAL FAIR HOUSING ACT (42 U.S.C. §§ 3604, 3605, 3617)

5.1. Plaintiff incorporates the preceding paragraphs.

5.2. 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].

5.3. [If financing-related:] Defendant's conduct violated 42 U.S.C. § 3605 by discriminating in a residential real estate-related transaction.

5.4. 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.

5.5. Defendant acted intentionally and/or its facially neutral policy had an unjustified discriminatory effect (disparate impact cognizable under the FHA per Texas Dep't of Housing & Community Affairs v. Inclusive Communities Project, Inc., 576 U.S. 519 (2015)).

5.6. This Count is timely under 42 U.S.C. § 3613(a). Plaintiff is entitled to actual and punitive damages, injunctive relief, and reasonable attorneys' fees and costs under 42 U.S.C. § 3613(c).

6. COUNT II — 42 U.S.C. § 1982 (EQUAL PROPERTY RIGHTS) [IF RACE-BASED]

6.1. Plaintiff incorporates the preceding paragraphs.

6.2. 42 U.S.C. § 1982 guarantees all citizens the same right "as is enjoyed by white citizens" to inherit, purchase, lease, sell, hold, and convey real and personal property.

6.3. Defendant denied or impaired Plaintiff's exercise of that right on the basis of race, entitling Plaintiff to compensatory and punitive damages and injunctive relief.

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

7.1. Plaintiff incorporates the preceding paragraphs.

7.2. Plaintiff is a person with a disability under 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, and Defendant was required to engage in an interactive process.

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

7.5. Plaintiff is entitled to actual and punitive damages, injunctive relief (including an order compelling the accommodation/modification), and attorneys' fees and costs.

8. COUNT IV — WYOMING FAIR HOUSING ACT (Wyo. Stat. Ann. § 40-26-101 et seq.) [OPTIONAL]

8.1. Plaintiff incorporates the preceding paragraphs.

8.2. The Wyoming Fair Housing Act, Wyo. Stat. Ann. § 40-26-101 et seq., prohibits discrimination in the sale or rental of housing because of race, color, religion, sex, familial status, national origin, or disability (Wyo. Stat. Ann. § 40-26-103 and related sections).

8.3. Defendant's conduct violated the Wyoming Fair Housing Act, entitling Plaintiff to the relief authorized by that chapter, including injunctive relief, damages, and (as a prevailing party) reasonable attorneys' fees and costs. [Confirm the operative relief and prevailing-party provisions and the absence/availability of a state enforcement route.]

9. DAMAGES

9.1. 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.

9.2. Emotional distress damages: humiliation, embarrassment, anxiety, and loss of dignity. The federal FHA imposes no cap on compensatory damages.

9.3. Punitive damages: Defendant acted with malice or reckless or callous indifference to Plaintiff's federally protected rights, warranting punitive damages under 42 U.S.C. § 3613(c)(1) and 42 U.S.C. § 1982.

9.4. Civil penalties: in any action commenced by the United States/Attorney General, civil penalties as authorized by 42 U.S.C. § 3614.

9.5. Attorneys' fees and costs: under 42 U.S.C. § 3613(c)(2) (and, if the state count is pleaded, the Wyoming Fair Housing Act prevailing-party provision).

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

10. 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 emotional-distress damages;
• C. For punitive damages;
• D. For a declaration that Defendants' conduct violated the federal Fair Housing Act, 42 U.S.C. § 1982, and (if pleaded) the Wyoming Fair Housing Act;
• 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 attorneys' fees and costs under all applicable fee-shifting statutes;
• G. For pre- and post-judgment interest; and
• H. For such other and further relief as the Court deems just and proper.

11. DEMAND FOR JURY TRIAL

Plaintiff demands a trial by jury on all issues so triable pursuant to Fed. R. Civ. P. 38 and the Seventh Amendment to the United States Constitution. [If filed in Wyoming state court, substitute W.R.C.P. 38 and Wyo. Const. art. 1, § 9.]

12. VERIFICATION

I, [PLAINTIFF NAME], declare under penalty of perjury under the laws of the United States 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], Wyoming.

[____________________]

[PLAINTIFF NAME]

13. SIGNATURE AND SERVICE BLOCKS

Date: [__/__/____]

Respectfully submitted,

[LAW FIRM NAME]

By: [____________________]

[ATTORNEY NAME], Wyo. State Bar No. [______]

Attorney for Plaintiff

[STREET ADDRESS]

[CITY, STATE ZIP]

Telephone: [__________]

Email: [__________]

14. CERTIFICATE OF SERVICE

I certify that on [__/__/____] I caused a true and correct copy of the foregoing Complaint to be served on the following by [method — personal service / mail / electronic service per Fed. R. Civ. P. 5 (or W.R.C.P. 5 if in state court)]:

[SERVICE LIST WITH ADDRESSES]

[____________________]

[NAME / TITLE]

15. WYOMING PRACTICE NOTES

• No operative state fair-housing enforcement agency (CRITICAL). Wyoming has a Fair Housing Act on the books (Wyo. Stat. Ann. § 40-26-101 et seq.), but the Governor has not assigned enforcement authority to any state agency. As a result, there is no functioning Wyoming fair-housing enforcement agency and limited developed state-court authority interpreting the statute. The Wyoming Advisory Committee to the U.S. Commission on Civil Rights reported (June 2025) that the only practical avenue for redress in Wyoming is the federal Fair Housing Act through HUD.
• HUD/DOJ federal route. HUD investigates Wyoming fair-housing complaints out of its Region VIII office in Denver, Colorado. An aggrieved person may file an administrative complaint with HUD within one (1) year of the discriminatory act (42 U.S.C. § 3610(a)). HUD may refer matters to, and the U.S. Department of Justice may bring, pattern-or-practice or election cases (42 U.S.C. §§ 3612, 3614).
• Private federal civil action. Independent of any HUD complaint, an aggrieved person may file a private civil action under 42 U.S.C. § 3613 within two (2) years of the discriminatory housing practice (excluding time a HUD proceeding was pending). No administrative exhaustion is required. The action may be filed in the U.S. District Court for the District of Wyoming or, given concurrent jurisdiction under § 3613(a), in Wyoming state court.
• 42 U.S.C. § 1982. For race-based property discrimination, § 1982 provides an additional federal remedy reaching private conduct, with no exhaustion requirement and punitive damages available; its limitations period borrows Wyoming's residual personal-injury statute — confirm before filing.
• Protected classes. Federal FHA: race, color, religion, sex (including sexual orientation and gender identity per HUD policy and Bostock-informed enforcement), familial status, national origin, and disability. Wyoming's own statute tracks the federal classes and adds none; Wyoming has NO statewide source-of-income protection. Check for any applicable municipal ordinance (Wyoming localities have generally not enacted broader fair-housing ordinances).
• Remedies. Federal FHA private action (42 U.S.C. § 3613(c)): actual and punitive damages (uncapped compensatory), injunctive and declaratory relief, and reasonable attorneys' fees and costs. HUD administrative law judges may impose civil penalties; the DOJ may seek civil penalties under § 3614.
• Reporting gap. HUD received only about 203 fair-housing inquiries from Wyoming over a recent 10-year period — considered low and likely reflecting underreporting — with the large majority disability/reasonable-accommodation related. Practitioners should weigh fair-housing testing to establish patterns given the thin local enforcement infrastructure.

16. SOURCES AND REFERENCES

• 42 U.S.C. § 3601 et seq. — Fair Housing Act — https://www.justice.gov/crt/fair-housing-act-2
• 42 U.S.C. § 3604 (prohibited practices); § 3605 (real estate-related transactions); § 3613 (private action, 2-year SOL); § 3617 (interference)
• 42 U.S.C. § 1982 (equal property rights) — https://www.law.cornell.edu/uscode/text/42/1982
• 24 C.F.R. Part 100 — HUD Fair Housing regulations
• Wyo. Stat. Ann. § 40-26-101 et seq. (Wyoming Fair Housing Act) — https://wyoleg.gov/statutes/compress/title40.pdf
• Wyoming Advisory Committee to the U.S. Commission on Civil Rights, "Housing Discrimination: Examining Fair Housing Practices in Wyoming" (Policy Brief, June 2025) — https://www.usccr.gov/files/2025-06/wy-sac-policy-brief.pdf
• HUD Region VIII (Denver) Office of Fair Housing and Equal Opportunity — https://www.hud.gov/program_offices/fair_housing_equal_opp
• Texas Dep't of Housing & Community Affairs v. Inclusive Communities Project, Inc., 576 U.S. 519 (2015) (disparate impact under the 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 Wyoming must review and customize this document before filing. Verify all statutory citations, limitations periods, and court rules — and confirm the current status of any Wyoming state fair-housing enforcement mechanism — before use.