Fair Housing of Marin, a California Non-Profit Corporation v. Jack Combs, D.B.A. Waters Edge Apartments

Plaintiff Fair Housing of Marin (“Fair Housing”) brought action for illegal housing discrimination on the basis of race against Jack Combs, owner of the Waters Edge apartment complex in San Rafael, California. Fair Housing alleged that Combs violated the Fair Housing Act of 1968 ( 42 U.S.C. § 3604 ), the CM Rights Act of 1866 ( 42 U.S.C. § 1982 ), the California Fair Employment and Housing Act (CAL. GOV’T CODE § 12955), and the California Unfair Business Practices Act (CAL. BUS. & PROF. CODE § 17200, et seq.). In his answer Combs claimed, inter alia, that Fair Housing lacked standing to sue. The district court (N.D.Cal., Jenkins, J.) found that Fair Housing had standing and later sanctioned Combs for discovery abuses by striking his answer and entering default judgment against him prior to trial. The district court awarded the plaintiff compensatory damages of $24,377 and punitive damages of $74,400, and adopted the magistrate judge’s recommendation, made after a full hearing, of attorney’s fees and costs in the amount of $508,606.78.

Combs appeals, claiming that the district court erred in the following ways: 1) finding that Fair Housing had standing to sue; 2) imposing sanction…