Housing And Civil Enforcement Cases Documents

v.

L.T. JACKSON; and
L.T. JACKSON TRUST,

__________________________

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 L.T. Jackson is a resident of the state of Mississippi in the Southern District of Mississippi. Mr. Jackson is the owner and/or manager of numerous identified rental properties in the Jackson, Mississippi area, including, but not limited to, properties located at 5635 Queen Eleanor Lane, 631 Tifton Drive, 309 North Prentiss Street, 4620 Kirley Drive, and 166 York Drive. Mr. Jackson has owned and/or personally managed these rental properties at all times relevant to this case.
4. Defendant L.T. Jackson Trust, located in the Southern District of Mississippi in Canton, Mississippi, owns and/or manages most or all of the rental properties at issue in this case.
5. The identified 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
7. Since at least 1992 through the present, defendant, L.T. Jackson, has subjected numerous female tenants (and, on some occasions their minor daughters), and prospective female tenants of the rental properties owned and/or managed by him, to severe, pervasive, and unwelcome verbal and physical sexual advances. On numerous occasions, defendant, L.T. Jackson, made sexually suggestive comments to both the female tenants and their teenage daughters. Jackson also made physical advances towards the tenants such as unwanted touching of their breasts, buttocks, and other parts of their bodies.
8. Defendant, L.T. Jackson, has explicitly based the terms, conditions, and privileges of the women's tenancy on the granting of sexual favors. For example, Jackson requested sexual favors from the female tenants of his properties in exchange for forgiveness of rent, late rent charges, and security deposits. Jackson also threatened to take steps to evict female tenants who refused or objected to his sexual advances, and threatened other adverse action against the female tenants when they refused or objected to his sexual advances.
9. The consistent pattern of sexual advances towards female tenants and prospective tenants has created a longstanding hostile environment for female tenants living at defendants' properties.
10. The conduct of the defendants described in paragraphs 6-9 constitutes:
    1. 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);
    2. 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);
    3. 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); and
    4. Coercion, intimidation, threats, and 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.
11. The conduct of the defendants described above in paragraphs 6-9 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.
12. There are numerous persons, including past, current, and prospective tenants, who have been injured by, and have suffered damages as a result of, the defendants' conduct. These persons are aggrieved persons as defined in 42 U.S.C. § 3602(i)
13. The defendants' above-described 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 him from:
   1. Discriminating on the basis of sex against any person in any aspect of the rental of a dwelling;
   2. 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
   3. 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 such victims would have been in but for the discriminatory conduct of the defendants;
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).

JANET RENO
Attorney General

BILL LANN LEE
Acting Assistant Attorney General
Civil Rights Division

JOAN A. MAGAGNA
Chief, Housing and Civil Enforcement Section

ISABELLE M. THABAULT
Deputy Chief, Housing and Civil Enforcement Section
SCOTT P. MOORE
Attorney, Housing and Civil Enforcement Section
Civil Rights Division
U.S. Department of Justice
P.O. Box 65998
Washington, DC 20035-5998
(202) 307-3801

BRAD PIGOTT
United States Attorney

MITZI DEASE PAIGE
Assistant United States Attorney
188 East Capitol Street
Suite 500
Jackson, Mississippi 39201
(601) 973-2840 > >