U.S. Department
of Justice
United States V. Donald Sterling, Et Al. (C.D. Cal.)
ALBERTO GONZALES
Attorney General
WAN J. KIM
Assistant Attorney General
Civil Rights Division
STEVEN H. ROSENBAUM
Chief
KEISHA DAWN BELL
Deputy Chief
JULIE J. ALLEN
E-mail: julie.allen@usdoj.gov
MING-YUEN MEYER-FONG
E-mail: ming-yuen.meyer-fong@usdoj.gov
Attorneys
Housing & Civil Enforcement Section
Civil Rights Division
U.S. Department of Justice
950 Pennsylvania Avenue, N.W. - G Street
Washington, DC 20530
Tel: (202) 307-6275
Fax: (202) 514-1116
DEBRA WONG YANG
United States Attorney
LEON W. WEIDMAN
Chief, Civil Division
KEVIN B. FINN
Assistant United States Attorney
Calif. Bar No. 128072
E-mail: kevin.finn@usdoj.gov
Federal Building, Suite 7516
300 North Los Angeles Street
Los Angeles, CA 90012
Tel: (213) 894-6739
Fax: (213) 894-7327
Attorneys for Plaintiff
United States of America
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA
Plaintiff,
v.
DONALD STERLING, individually, in his
capacity as trustee for the Sterling Family Trust,
and doing business as Beverly Hills Properties; COMPLAINT
ROCHELLE STERLING, individually and in (And Demand for Jury Trial)
her capacity as trustee for the Sterling Family
Trust; STERLING FAMILY TRUST; and THE
KOREAN LAND COMPANY, L.L.C.
Defendants.
________________________________________ )
Plaintiff 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. (“Fair Housing Act”).
2.This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1345 and 42 U.S.C. § 3614(a).
3.Venue in this district is proper pursuant to 28 U.S.C. § 1391(b). The events or omissions giving rise to this claim occurred in the Central District of California; the property that is the subject of the action is situated in the Central District of California; and the Defendants conduct business in this District.
4.Defendant Donald Sterling and Defendant Rochelle Sterling are residents of Los Angeles, California, and are the owners and/or managers of numerous multi-family residential rental properties located in Los Angeles County, California.
5.Beverly Hills Properties is Donald Sterling’s “doing business as” name. Beverly Hills Properties manages multi-family residential rental properties located in Los Angeles County, California.
6.Defendant Sterling Family Trust holds title to and owns multi-family residential rental property in Los Angeles County.
7.At all times relevant to this Complaint, Defendants Donald Sterling and Rochelle Sterling have been trustees of the Defendant Sterling Family Trust, and are sued herein both individually and as trustees of the Sterling Family Trust.
8.Defendant Korean Land Company is a California limited liability company that holds title to and owns multi-family residential rental property in Los Angeles County.
9.Defendants’ multi-family residential rental properties in Los Angeles County are dwellings within the meaning of the Fair Housing Act, 42 U.S.C. § 3602(b).
10.Defendants Donald Sterling, Rochelle Sterling, and their agents and/or employees have engaged in a pattern or practice of discrimination on the basis of race, national origin, and familial status in connection with the rental of dwellings owned by the Korean Land Company, the Sterling Family Trust, and Donald and Rochelle Sterling, in violation of the Fair Housing Act.
11.Donald Sterling, Rochelle Sterling, the Korean Land Company, and the Sterling Family Trust have, at all times relevant to this Complaint, had the authority to control and direct the agents who committed the discriminatory actions stated herein.
12.The Defendants and their agents have engaged in a pattern or practice of discrimination by, among other ways:
(a) Refusing to rent to non-Koreans at the multi-family residential rental properties that Defendants own or manage, or have owned or managed, in the Koreatown section of Los Angeles County;
(b) Refusing to rent to African-Americans at the multi-family residential rental properties that Defendants own or manage, or have owned or managed, in the Beverly Hills section of Los Angeles County;
(c) Refusing to rent to families with children at the multi-family residential rental properties that Defendants own or manage, or have owned or managed, in Los Angeles County;
(d) Creating, maintaining, and perpetuating an environment that is hostile to non-Korean tenants at the multi-family residential rental properties that Defendants own or manage, or have owned or managed, in the Koreatown section of Los Angeles County;
(e) Providing inferior treatment to non-Korean tenants in the terms, conditions, and/or privileges of a rental at the multi-family residential rental properties that Defendants own or manage, or have owned or managed, in the Koreatown section of Los Angeles County;
(f) Misrepresenting the availability of units to non-Koreans at the multi-family residential rental properties that Defendants own or manage, or have owned or managed, in the Koreatown section of Los Angeles County;
(g) Misrepresenting the availability of units to African-Americans at the multi-family residential rental properties that Defendants own or manage, or have owned or managed, in the Beverly Hills section of Los Angeles County;
(h) Misrepresenting the availability of units to families with children at the multi-family residential rental properties that Defendants own or manage, or have owned or managed, in Los Angeles County;
(i) Making statements and publishing notices or advertisements in connection with the rental of units that express a preference for Korean tenants and discrimination against non-Korean tenants; and
(j) Making statements or publishing notices or advertisements in connection with the rental of units that express discrimination against African-Americans and families with children as tenants.
13.At all relevant times Defendants Donald Sterling, Rochelle Sterling, their agents and/or their employees committed the discriminatory acts contained in Paragraph 12 as agents for the Korean Land Company, the Sterling Family Trust, or Donald and Rochelle Sterling.
14.The conduct of the Defendants as described in Paragraph 12, constitutes:
(a) A refusal to rent, a refusal to negotiate for the rental of, and conduct otherwise making unavailable or denying dwellings to persons because of race, national origin, and familial status, in violation of 42 U.S.C. § 3604(a);
(b) Discrimination in the terms, conditions, or privileges, of rental of dwellings on the basis of race or national origin, in violation of 42 U.S.C. § 3604(b);
(c) Statements of preference or limitation on the basis of race, national origin and familial status in connection with the rental of dwellings, in violation of 42 U.S.C. § 3604(c);
(d) Publications or notices of preference or limitation on the basis of race or national origin in connection with the rental of dwellings, in violation of 42 U.S.C. § 3604(c); and
(e) Misrepresentations regarding the availability of units on the basis of race, national origin and familial status, in violation of 42 U.S.C. § 3604(d).
15.The conduct of Defendants, as described herein, was intentional, willful, and taken in disregard for the rights of others.
16.The conduct of the Defendants described in Paragraph 12 constitutes:
(a)A pattern or practice of resistance to the full enjoyment of rights secured 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.
17.Individuals who were subjected to Defendants’ discriminatory housing practices are aggrieved persons as defined by the Fair Housing Act, 42 U.S.C. § 3602(i), and have suffered actual injury and damages as a result of Defendants’ conduct as described herein.
WHEREFORE, the United States prays that the Court enter an order that:
A.Declares that Defendants’ policies and practices, as alleged herein, violate the Fair Housing Act, as amended, 42 U.S.C. §§ 3601 et seq.;
B. Enjoins the Defendants, their agents, employees, and successors, and all other persons in active concert or participation with them from:
(1)Discriminating on account of race, national origin, and familial status against any person in any aspect of the rental of a dwelling; and
(2)Interfering with any person in the exercise or enjoyment of rights granted or protected by the Fair Housing Act.
C. Awards monetary damages to each person aggrieved by Defendants’ discriminatory housing practices, pursuant to 42 U.S.C. § 3614(d)(1)(B) ; and
E.Assesses a civil penalty against each Defendant in order to vindicate the public interest, pursuant to Section 814(d)(1)(C) of the Fair Housing Act, 42 U.S.C. § 3614(d)(1)(C).
The United States further prays for such additional relief as the interests of justice may require.
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, the United States of America hereby demands a trial by jury of this action of all issues triable of right to a jury.
ALBERTO GONZALES
Attorney General
_______________________ _______________________
DEBRA WONG YANG WAN J. KIM
United States AttorneyAssistant Attorney General
Civil Rights Division
_______________________
LEON W. WEIDMANSTEVEN H. ROSENBAUM
Chief, Civil DivisionChief, Housing and Civil
Enforcement Section
Civil Rights Division
_______________________
KEVIN B. FINNKEISHA DAWN BELL
Assistant United States AttorneyDeputy Chief
Calif. Bar No. 128072 JULIE J. ALLEN
E-mail: kevin.finn@usdoj.gov E-mail: julie.allen@usdoj.gov
Federal Building, Suite 7516 MING-YUEN MEYER-FONG
300 North Los Angeles Street E-mail: ming-yuen.meyer-fong@usdoj.gov
Los Angeles, CA 90012 Attorney s
Tel: (213) 894-6739 Housing and Civil Enforcement Section
Fax: (213) 894-7327 Civil Rights Division
U.S. Department of Justice
950 Pennsylvania Ave., N.W. - G St.
Washington, D.C. 20530
Phone: (202) 307-6275
Fax: (202) 514-1116
Document Filed: August 7, 2006 > >