IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
UNITED STATES OF AMERICA,
RONALD STEVENS and
PARTNERS; GUNTRAN WEISENBERG;
and IRENE HAMMOND,
The United States of America alleges:
- This action is brought by the United States to enforce
the Fair Housing Act, Title VIII of the Civil Rights Act of 1968,
as amended by the Fair Housing Amendments Act of 1988, 42 U.S.C.
§§ 3601 et seq.
- This Court has jurisdiction over this action under
28 U.S.C. § 1345 and 42 U.S.C. § 3614.
- The Knollwood Apartments is a 91-unit apartment complex
located at 30 Nutt Road in Phoenixville, Pennsylvania.
- Defendants, Ronald Stevens and Byron Anstine, were,
from December, 1980 through November 2, 1998, the owners of the
Knollwood Apartment complex which is located in the District of
- Defendant, Guntran Weisenberg, acquired title to
Knollwood Apartments on November 2, 1998, and is now the current
- Defendant Irene Hammond is the rental manager of
Knollwood Apartments and does business in the District of
- The apartments at Knollwood Apartments are dwellings
within the meaning of the Fair Housing Act, 42 U.S.C. § 3602(b).
- The United States Department of Justice conducted an
investigation to determine defendants' compliance with the Fair
Housing Act. As part of its investigation, the Department of
Justice, with the assistance of the Fair Housing Council of
Suburban Philadelphia, conducted a series of tests to evaluate
the defendants' compliance with the Fair Housing Act.
- The investigation revealed that the defendants are
engaged in housing practices that discriminate on the basis of
familial status at Knollwood Apartments, including:
- Limiting families with children to rental of only
first floor apartments while permitting persons with no
children to rent any vacant units in the complex;
- Representing to persons inquiring about apartments
that families with children were not permitted to
occupy apartments above the first floor;
- Discouraging persons with children from renting at
Knollwood at all, while encouraging persons without
children to rent there; and
- Failing to provide the same information about
apartment availabilities to persons with children as
provided to persons without children.
- The conduct of the defendants described in the previous
numbered paragraph constitutes:
- Refusal to rent a dwelling to persons because of
their familial status in violation of §3604(a);
- Discrimination in the terms and conditions, or
privileges of the rental of a dwelling that
indicates a preference or discrimination on the
basis of familial status in violation of 42 U.S.C.
- Statements made with respect to the rental of a
dwelling that indicate a preference or
discrimination based on a person's familial status
in violation of 42 U.S.C. §3604(c); and
- A representation to persons because of their
familial status that dwellings are not available
for rental when such dwellings are in fact so
available in violation of 42 U.S.C. § 3604(d).
- The conduct of the defendants described above
constitutes a pattern or practice of resistance to the full
enjoyment of rights granted by the Fair Housing Act.
- The defendants' conduct described above was
intentional, willful, and taken in disregard for the rights of
WHEREFORE, the United States prays that the Court enter an
- Declares that the defendants' policies and practices,
as alleged herein, violate the Fair Housing Act;
- Enjoins the defendants, their officers, employees, and
agents, and all other persons in active concert or participation
with defendants, from:
- Discriminating against any person on the basis of
familial status in any aspect of the rental of a
- Failing or refusing to notify the public that
dwellings owned or operated by the defendants are
available to all persons on a nondiscriminatory basis;
- Failing or refusing to take such affirmative steps
as may be necessary to restore, as nearly as
practicable, the victims of the defendants' unlawful
practices to the position that they would have been in
but for the discriminatory conduct;
- Awards such damages as would fully compensate each per-son aggrieved by the defendants' discriminatory housing practices
for injuries caused by the defendants' pattern or practice of
discriminatory conduct, pursuant to 42 U.S.C. § 3614(d)(1)(B);
- Awards each person aggrieved by defendants'
discriminatory conduct punitive damages because of the
intentional and willful nature of the defendants' conduct,
pursuant to 42 U.S.C. § 3614(d)(1)(B); and
- Assesses a civil penalty against the defendants in the
amount authorized by 42 U.S.C. § 3614(d)(1)(C), in order to
vindicate the public interest.
The United States further prays for such additional relief
as the interests of justice may require.
BILL LANN LEE
Acting Assistant Attorney General
Civil Rights Division
JOAN A. MAGAGNA
Chief, Housing and Civil Enforcement Section
Civil Rights Division
ISABELLE M. THABAULT
CHARLA D. JACKSON
U.S. Department of Justice
Civil Rights Division
Housing and Civil Enforcement Section
P.O. Box 65998
Washington, D.C. 20035-5998