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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF OHIO
EASTERN DIVISION

UNITED STATES OF AMERICA,

Plaintiff

v.

PAUL F. CRAWFORD and
CRAWFORD LUMBER CO., INC.

Defendants.

__________________________

COMPLAINT

The United States of America alleges:

1. This action is brought by the United States to enforce the provisions of Title VIII of the Civil Rights Act of 1968 (the Fair Housing Act), as amended by the Fair Housing Amendments Act of 1988, 42 U.S.C. §§ 3601, et seq.

2. This court has jurisdiction over this action under 28 U.S.C. § 1331, 28 U.S.C.§ 1345 and 42 U.S.C. § 3614(a).

3. Defendant Paul Crawford is a resident of Akron in the Northern District of Ohio. Mr. Crawford is the manager of numerous rental properties in the Akron, Ohio area, and has acted in that capacity for the rental properties at issue in this case at all relevant times. At all relevant times, Mr. Crawford has also been president and shareholder of defendant Crawford Lumber Co., Inc.

4. Defendant Crawford Lumber Co., Inc., a domestic corporation located in the Northern District of Ohio at 1439 Kenmore Blvd., Akron, Ohio 44314, owns most or all of the rental properties at issue in this case.

5. The rental properties owned and/or managed by defendants are dwellings within the meaning of 42 U.S.C. § 3602(b).

6. The defendants have violated the Fair Housing Act, 42 U.S.C. §§ 3601, et seq., by discriminating against persons on the basis of sex in connection with the rental of dwellings, including those located at 247 Ira Avenue, 909 Oregon Avenue, 1081 Florida Avenue, 2180 5th Street, 774 Krause Court, 1145 Kenmore Boulevard, and 1164 Victory Street, all in Akron, Ohio.

7. From at least 1995 through the present, defendant Paul Crawford has subjected many female tenants and prospective female tenants of the rental properties owned by defendant Crawford Lumber Company, including Betty Pryor, Cynthia Walker, Shirley Gary, Vanessa Williams, Betty Brown, and Robin Payne, to severe, pervasive, and unwelcome sexual harassment, including: multiple instances of unwanted verbal sexual advances; multiple instances of unwanted sexual touching; conditioning the terms and conditions of women's tenancy on the granting of sexual favors; and threatening and taking steps to evict or take other adverse action against female tenants and prospective tenants when they refused or objected to his sexual advances.

8. The conduct of the defendants described above constitutes:

a. A denial or making unavailable of housing because of sex, in violation of Section 804(a) of the Fair Housing Act, 42 U.S.C. § 3604(a);

b. Discrimination in the terms, conditions, or privileges of the rental of dwellings, or in the provision of services or facilities in connection therewith, because of sex, in violation of Section 804(b) of the Fair Housing Act, 42 U.S.C. § 3604(b);

c. The making of statements with respect to the rental of dwellings that indicate a preference, limitation, or discrimination based on sex, in violation of Section 804(c) of the Fair Housing Act, 42 U.S.C. § 3604(c); and

d. Coercion, intimidation, threats, or interference with persons in the exercise or enjoyment of, or on account of their having exercised or enjoyed, their rights under Section 804 of the Fair Housing Act, in violation of Section 818 of the Fair Housing Act, 42 U.S.C. § 3617.

9. The conduct of the defendants described above constitutes:

a. A pattern or practice of resistance to the full enjoyment of rights granted by the Fair Housing Act, 42 U.S.C. §§ 3601 et seq.; and

b. A denial to a group of persons of rights granted by the Fair Housing Act, 42 U.S.C. §§ 3601 et seq., which denial raises an issue of general public importance.

10. Betty Pryor, Cynthia Walker, Shirley Gary, Vanessa Williams, Betty Brown, and Robin Payne are aggrieved persons as defined in 42 U.S.C. § 3602(i) and have suffered damages as a result of the defendants' conduct.

11. There may be numerous other female victims of the defendants' practices who were prospective or actual tenants of the properties owned and managed by the defendants. Such victims are aggrieved persons as defined in 42 U.S.C. § 3602(i) and have suffered damages as a result of the defendants' conduct.

12. The defendants' conduct was intentional, willful, and taken in disregard for the rights of others.

WHEREFORE, the United States prays that the Court enter an ORDER that:

1. Declares that the defendants' discriminatory practices violate the Fair Housing Act, as amended, 42 U.S.C. §§ 3601 et seq.;

2. Enjoins the defendants, their agents, employees, and successors, and all other persons in active concert or participation with them from:

a. Discriminating on account of sex against any person in any aspect of the rental of a dwelling;

b. Interfering with or threatening to take any action against any person in the exercise or enjoyment of rights granted or protected by the Fair Housing Act, as amended; and

c. Failing or refusing to take such affirmative steps as may be necessary to restore, as nearly as practicable, the victims of the defendants' past unlawful practices to the position they would have been in but for the discriminatory conduct;

3. Awards such damages as would fully compensate each identifiable victim of defendants' discriminatory housing practices for injuries caused by the defendants' discriminatory conduct, pursuant to 42 U.S.C. § 3614(d)(1)(B);

4. Awards punitive damages to each identifiable victim of defendants' discriminatory housing practices, pursuant to 42 U.S.C. § 3614(d)(1)(B); and

5. Assesses a civil penalty against the defendants in order to vindicate the public interest, pursuant to 42 U.S.C. § 3614(d)(1)(C).

The United States further prays for such additional relief as the interests of justice may require.

JANET RENO,
Attorney General

EMILY M. SWEENEY,
United States Attorney

MICHAEL ANNE JOHNSON #0010269,
Assistant United States Attorney
1800 Bank One Center
600 Superior Avenue East
Cleveland, OH 44114-2600
216) 622-3689

BILL LANN LEE,
Acting Assistant Attorney General
Civil Rights Division

JOAN A. MAGAGNA,
Acting Chief
Housing and Civil Enforcement Section

ROBERT S. BERMAN
ELIZABETH A. SINGER
JEFFREY M. SENGER
BARBARA A. BURR,
Attorneys
Housing and Civil Enforcement Section
Civil Rights Division
U.S. Department of Justice
P.O. Box 65998
Washington, DC 20035-5998
(202) 514-6164

General Information Housing and Civil Enforcement Section
 
Leadership
Steven H. Rosenbaum
Chief
Contact
Housing & Civil
Enforcement Section
(202) 514-4713
TTY - 202-305-1882
FAX - (202) 514-1116
To Report an Incident of Housing Discrimination:
1-800-896-7743
Mailing Contact
U.S. Department of Justice
Civil Rights Division
950 Pennsylvania Avenue, N.W.
Housing and Civil Enforcement Section, NWB
Washington, D.C. 20530

Email: fairhousing@usdoj.gov

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