El Dorado Estates v. City of Fillmore

Fair housing is the topic of the day, as we are presented with a case involving the Fair Housing Act (“FHA”). El Dorado Estates (“El Dorado”), is a mobile home park owner located in the City of Fillmore (“City”), California. Litigation between El Dorado and the City arose out of El Dora-do’s application for a subdivision of its seniors-only mobile home park, the El Do-rado Estates Mobile Home Park (the “Park”). In its complaint, El Dorado alleges that the City interfered with the application by causing unreasonable delays and imposing extralegal conditions because of a fear that subdivision would lead to El Dorado opening the Park to families.

Protracted state court proceedings surrounding the legality of various conditions the City imposed on El Dorado when processing its subdivision application eventually led to El Dorado bringing this action in federal court, alleging that the City’s actions violated various provisions of the FHA. El Dorado’s complaint was dismissed by the district court for lack of standing under Article III.

We disagree that El Dorado lacks Article III standing. When the injury suffered by El Dorado is construed as alleged in El Dorado’s complaint,…