UNITED STATES OF AMERICA,
     Plaintiff,

v.

SLEEPY HOLLOW ESTATES, INC.
AND JESSIE ROBERTS,
     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(a).

3. Defendant Sleepy Hollow Estates, Inc. is a North Carolina corporation that is doing business and operating in the Middle District of North Carolina. Sleepy Hollow Estates, Inc. owns Sleepy Hollow Estates, a mobile home park containing approximately 100 lots located at 2833 Highway South NC 87, Graham, Alamance County, North Carolina, in the Middle District of North Carolina. Sleepy Hollow Estates, Inc. also acts as a mobile home dealer selling mobile homes for placement in Sleepy Hollow Estates.

4. Defendant Jessie Roberts is a founding director of Sleepy Hollow Estates, Inc. and the manager of Sleepy Hollow Estates and has responsibility for the rental of mobile home lots and the sale of new homes to be placed on lots at Sleepy Hollow Estates. Jessie Roberts resides in the Middle District of North Carolina.

5. The mobile homes and vacant lots located at Sleepy Hollow Estates are dwellings within the meaning of the Fair Housing Act, 42 U.S.C. § 3602(b).

6. The United States, through its Department of Justice, conducted an investigation of the rental and sales policies and practices implemented at Sleepy Hollow Estates to evaluate compliance with the Fair Housing Act. As part of this investigation, the United States conducted a series of fair housing tests from October 1997 through July 1998, using testers to compare the information provided and the services and treatment afforded by Defendants to different types of prospective renters or purchasers. Testers are persons who, without the intent to rent or buy a dwelling, gather information about housing for rent or sale in order to help determine whether or not discriminatory housing practices are occurring.

7. The investigation conducted by the United States revealed that Defendants, individually and through their agent, engage in discriminatory practices, including:
   1. Making explicit statements with respect to the rental of lots and the sale of homes that indicate a clear preference, policy and intent to limit and exclude black persons, including at least one bona fide homeseeker, from residing in the park;

   2. Denying the availability of lots for rent and homes for sale to black persons while at the same time telling white persons about available lots for rent and homes for sale;

   3. Permitting white persons to inspect homes available for sale while at the same time representing to black persons that there are no homes available for inspection; and

   4. Encouraging white persons to apply for tenancy, including offering to hold vacant homes or lots, while at the same time withholding such encouragement from black persons.

8. As described above, Defendants have engaged in discrimination against persons because of race and color in the sale and rental of dwellings in violation of the Fair Housing Act. Defendants have implemented this unlawful discrimination, among other ways, by:
   1. Making unavailable dwellings to persons because of race and color, in violation of 42 U.S.C. § 3604(a);

   2. Making statements with respect to the rental or sale of dwellings that indicate a preference, limitation or discrimination based on race and color, or an intention to make such preference, limitation, or discrimination, in violation of 42 U.S.C. § 3604(c); and

   3. Representing to persons because of race and color that dwellings are not available for inspection, rental, or sale when such dwellings are in fact so available, in violation of 42 U.S.C. § 3604(d).

9. The conduct of Defendants as described above constitutes:
   1. 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

   2. 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. There may be persons who have been victims of Defendants' discriminatory housing practices and who may have suffered damages as a result of Defendants' conduct described above. Such persons are aggrieved persons as defined in 42 U.S.C. § 3602(i).

11. Defendants' conduct described above was intentional, willful, and taken in reckless disregard for the rights of others.

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

1. Declares that Defendants' policies and practices, as alleged herein, violate the Fair Housing Act;

2. Enjoins Defendants, their officers, employees, and agents, and all other persons in active concert or participation with any of them, from:
   1. Discriminating because of race or color against any person in any aspect of the rental or sale of a dwelling;

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

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

   4. Failing or refusing to take such affirmative steps as may be necessary to prevent the recurrence of any discriminatory conduct in the future and to eliminate, to the extent practicable, the effects of Defendants' unlawful housing practices.

3. Awards such damages as would fully compensate each person aggrieved by Defendants' discriminatory housing practices for injuries caused by Defendants' pattern or practice of discriminatory conduct, pursuant to 42 U.S.C. § 3614(d)(1)(B);

4. Awards each person aggrieved by Defendants' pattern or practice of discrimination punitive damages, pursuant to 42 U.S.C. § 3614(d)(1)(B); and

5. Assesses a civil penalty against each defendant 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

Joseph D. Rich
Deputy Chief
Clay G. Guthridge
Eric I. Halperin
Attorneys
U.S. Department of Justice
Civil Rights Division
Housing and Civil Enforcement Section
P.O. Box 65998
Washington, D.C. 20035-5998
(202) 353-9706

Walter C. Holton, Jr.
United States Attorney

Gill P. Beck
Assistant United States Attorney
101 S. Edgeworth St. 4^th Fl.
Greensboro, NC 27401
(910) 333-5351