Housing And Civil Enforcement Cases Documents

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ALABAMA
NORTHERN DIVISION


UNITED STATES OF AMERICA,
     Plaintiff,

v.

CIVIL ACTION NO. 01-0046-CB-L

SATYAM, L.L.C., d/b/a Selma
Comfort Inn; NAVINABHAI
PATEL; and HINANAVINABHAI
PATEL,
     Defendants.

______________________________


PLAINTIFF UNITED STATES' COMPLAINT FOR INJUNCTIVE RELIEF

The United States of America alleges that:

  1. This action is brought by the Attorney General on behalf of the United States to enforce Title II of the Civil Rights Act of 1964 (the Public Accommodations Act), 42 U.S.C. §§ 2000a et seq.
Jurisdiction
  1. This Court has jurisdiction of this action pursuant to 42 U.S.C. § 2000a-5(a) and 28 U.S.C. § 1345.
  2. Venue is proper in the Southern District of Alabama because the claims alleged here arose in this District and the Defendants do business here.
Parties
  1. Defendant Satyam, L.L.C. is an Alabama limited liability company. Satyam does business as and operates the Comfort Inn in Selma, Alabama. This hotel is located at 1812 Highway 14 East in the Southern District of Alabama.
  2. Defendant Navinabhai Patel served as the general manager of the Selma Comfort Inn from approximately April 1999 through October 2000 and held himself out as being a part owner of the hotel. He is also known as Nick Patel and is married to Defendant Hinanavinabhai Patel. Upon information and belief, he currently resides in Mississippi.
  3. Defendant Hinanavinabhai Patel performed desk clerk and housekeeping duties at the Selma Comfort Inn from approximately April 1999 through August 2000. She is also known as Hina Patel and is married to Defendant Nick Patel. Upon information and belief, she currently resides in Mississippi.
  4. The Selma Comfort Inn is a fifty (50) unit facility that provides lodging to transient guests. It is a franchise of Choice Hotels International, Inc., a large international lodging chain.
  5. The Selma Comfort Inn is a place of public accommodation within the meaning of 42 U.S.C. § 2000a(b)(1).
  6. The operation of the Selma Comfort Inn affects commerce within the meaning of 42 U.S.C. § 2000a(c)(1).
Title II Violations
  1. Defendants, through their own actions, or the actions of their employees or agents, have implemented a policy and practice of denying to African Americans, on account of race or color, the full and equal enjoyment of their goods, services, facilities, privileges, advantages, and accommodations, on the same basis as they make them available to white persons. Defendants and their agents have carried out this policy and practice by, among other things:
    1. Steering African American guests to rooms on the second floor of the hotel towards the back solely on the basis of race or color;
    2. Denying African American guests an opportunity to rent rooms on the first floor of the hotel while making these rooms available to white persons;
    3. Denying African American guests an opportunity to rent suites - which have more amenities and are more desirable than regular rooms at the hotel - while making suites available to white persons;
    4. Falsely telling African American guests that suites and first floor rooms were not available while telling white patrons that these rooms were available;
    5. Charging African American guests higher prices for renting rooms at the hotel than they charged white persons for the same type of room; and
    6. Denying African American guests access to facilities and services of the hotel, such as the pool, on the same terms and conditions as these facilities and services were available to white guests.
  2. The conduct of Defendants described in Paragraph 10 constitutes a pattern or practice of resistance to the full and equal enjoyment by African Americans of rights secured by 42 U.S.C. §§ 2000a et seq., and the pattern or practice is of such a nature and is intended to deny the full exercise of such rights. Unless restrained by Order of this Court, Defendants will continue to refuse to provide African Americans with the full and equal enjoyment of rights secured to them by 42 U.S.C. §§ 2000a et seq.
Prayer for Relief

WHEREFORE, the United States requests that the Court enter an Order:

  1. Declaring that the discriminatory practices and policies of the Defendants violate Title II of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000a et seq.;
  2. Enjoining Defendants, their employees, agents, and successors, and all other persons in active concert or participation with them, from engaging in any act or practice which, on the basis of race or color, denies or abridges any rights secured by Title II of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000a et seq.; and
  3. Requiring Defendants, their employees, agents, and successors, and all other persons in active concert or participation with any of them, to take such affirmative steps as may be necessary to remedy the past unlawful conduct.

The United States further prays for such additional relief as the interests of justice may require, together with the costs and disbursements of this action.


  JANET RENO
Attorney General

J. DON FOSTER
United States Attorney
63 South Royal Street
Suite 600
Mobile, Alabama 36602
(334) 441-5845
(334) 441-5277 (fax)
BILL LANN LEE
Assistant Attorney General
Civil Rights Division
 
JOAN M. MAGAGNA
Chief
Housing and Civil Enforcement Section
 
ISABELLE M. THABAULT
Deputy Chief
ELLEN M. BOWDEN
Trial Attorney
Housing and Civil Enforcement Section
Civil Rights Division
U.S. Department of Justice
P.O. Box 65998
Washington, D.C. 20035-5998
(202) 305-0835
(202) 514-1116 (fax)

Document Filed: January 19, 2001. > >

Updated August 6, 2015

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