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