UNITED STATES OF AMERICA,
     Plaintiff,

v.

RONALD STEVENS and
BYRON ANSTINE
d/b/a KNOLLWOOD
PARTNERS; GUNTRAN WEISENBERG;
and IRENE HAMMOND,
     Defendants.

__________________________________

The United States of America alleges:

1. 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.

2. This Court has jurisdiction over this action under 28 U.S.C. § 1345 and 42 U.S.C. § 3614.

3. The Knollwood Apartments is a 91-unit apartment complex located at 30 Nutt Road in Phoenixville, Pennsylvania.

4. 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 Pennsylvania.

5. Defendant, Guntran Weisenberg, acquired title to Knollwood Apartments on November 2, 1998, and is now the current owner.

6. Defendant Irene Hammond is the rental manager of Knollwood Apartments and does business in the District of Pennsylvania.

7. The apartments at Knollwood Apartments are dwellings within the meaning of the Fair Housing Act, 42 U.S.C. § 3602(b).

8. 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.

9. The investigation revealed that the defendants are engaged in housing practices that discriminate on the basis of familial status at Knollwood Apartments, including:
   1. 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;

   2. Representing to persons inquiring about apartments that families with children were not permitted to occupy apartments above the first floor;

   3. Discouraging persons with children from renting at Knollwood at all, while encouraging persons without children to rent there; and

   4. Failing to provide the same information about apartment availabilities to persons with children as provided to persons without children.

10. The conduct of the defendants described in the previous numbered paragraph constitutes:
    1. Refusal to rent a dwelling to persons because of their familial status in violation of §3604(a);

    2. 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. §3604(b);

    3. 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

    4. 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).

11. 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.

12. The defendants' conduct described above 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' policies and practices, as alleged herein, violate the Fair Housing Act;

2. Enjoins the defendants, their officers, employees, and agents, and all other persons in active concert or participation with defendants, from:
   1. Discriminating against any person on the basis of familial status in any aspect of the rental of a dwelling;

   2. Failing or refusing to notify the public that dwellings owned or operated by the defendants are available to all persons on a nondiscriminatory basis; and

   3. 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;

3. 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);

4. 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

5. 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.

JANET RENO
Attorney General

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
Deputy Chief

CHARLA D. JACKSON
Attorney
U.S. Department of Justice
Civil Rights Division
Housing and Civil Enforcement Section
P.O. Box 65998
Washington, D.C. 20035-5998
(202) 353-9705