Fourth Department – Landlord/tenant: Housing Opportunities Made Equal v. DASA Properties LLC – NY Daily Record
Fourth+Department+%E2%80%93+Landlord%2Ftenant%3A+ ... NY Daily Record
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New York State Supreme Court, Appellate Division, Fourth Judicial Department
Landlord/Tenant: Discrimination – Lawful Source of Income
Housing Opportunities Made Equal v. DASA Properties LLC
CA 22-01578
Appealed from Supreme Court, Erie County
Background
The plaintiff, Housing Opportunities Made Equal, filed a lawsuit seeking compensatory and punitive damages against DASA Properties LLC for alleged discriminatory conduct based on potential renters’ lawful source of income. The plaintiff conducted tests by sending individuals to DASA Properties LLC’s properties to inquire about renting. These testers asked if the defendants accepted security agreements issued by the Department of Social Services, which serve as an alternative to cash deposits. The defendants responded that they accepted these agreements but required tenants to provide a cash deposit equal to half a month’s rent in addition to the security agreement. The plaintiffs appealed after the defendants’ motion to dismiss was granted.
Ruling
The Appellate Division reversed the decision. The court determined that the allegations in the amended complaint supported the inference that the defendants imposed different terms or conditions for rental on individuals whose lawful source of income was public assistance compared to those with other sources of income.
Jared Waldron, of Civil Rights & Transparency Clinic, represented the plaintiff-appellant; Nicholas M. Hriczko, of Chelus, Herdzik, Speyer & Monte, represented the defendants-respondents.
Watch the oral argument video here
SDGs, Targets, and Indicators Analysis
1. Which SDGs are addressed or connected to the issues highlighted in the article?
- SDG 1: No Poverty
- SDG 10: Reduced Inequalities
- SDG 11: Sustainable Cities and Communities
The article discusses discrimination based on potential renters’ lawful source of income, which connects to SDG 1 (No Poverty) as it aims to eradicate poverty in all its forms. It also addresses SDG 10 (Reduced Inequalities) as it highlights the discriminatory conduct faced by individuals with public assistance as their lawful source of income. Additionally, the issue of discrimination in housing opportunities relates to SDG 11 (Sustainable Cities and Communities) as it emphasizes the importance of creating inclusive and sustainable urban environments.
2. What specific targets under those SDGs can be identified based on the article’s content?
- Target 1.4: By 2030, ensure that all men and women, in particular, the poor and the vulnerable, have equal rights to economic resources, as well as access to basic services, ownership, and control over land and other forms of property.
- Target 10.3: Ensure equal opportunity and reduce inequalities of outcome, including by eliminating discriminatory laws, policies, and practices and promoting appropriate legislation, policies, and action in this regard.
- Target 11.1: By 2030, ensure access for all to adequate, safe, and affordable housing and basic services and upgrade slums.
Based on the article’s content, the specific targets identified are Target 1.4 (No Poverty), Target 10.3 (Reduced Inequalities), and Target 11.1 (Sustainable Cities and Communities). These targets aim to address the issues of equal rights to economic resources, eliminating discriminatory practices, and ensuring access to adequate housing and basic services.
3. Are there any indicators mentioned or implied in the article that can be used to measure progress towards the identified targets?
- Indicator 1.4.2: Proportion of total adult population with secure tenure rights to land, with legally recognized documentation, and who perceive their rights to land as secure, by sex and type of tenure.
- Indicator 10.3.1: Proportion of population reporting having personally felt discriminated against or harassed in the previous 12 months on the basis of a ground of discrimination prohibited under international human rights law.
- Indicator 11.1.1: Proportion of urban population living in slums, informal settlements, or inadequate housing.
The article does not explicitly mention indicators, but based on the identified targets, the following indicators can be used to measure progress towards those targets. Indicator 1.4.2 measures the proportion of the population with secure tenure rights to land, Indicator 10.3.1 measures the proportion of the population reporting discrimination, and Indicator 11.1.1 measures the proportion of the urban population living in inadequate housing.
SDGs, Targets, and Indicators Table
| SDGs | Targets | Indicators |
|---|---|---|
| SDG 1: No Poverty | Target 1.4: By 2030, ensure that all men and women, in particular, the poor and the vulnerable, have equal rights to economic resources, as well as access to basic services, ownership, and control over land and other forms of property. | Indicator 1.4.2: Proportion of total adult population with secure tenure rights to land, with legally recognized documentation, and who perceive their rights to land as secure, by sex and type of tenure. |
| SDG 10: Reduced Inequalities | Target 10.3: Ensure equal opportunity and reduce inequalities of outcome, including by eliminating discriminatory laws, policies, and practices and promoting appropriate legislation, policies, and action in this regard. | Indicator 10.3.1: Proportion of population reporting having personally felt discriminated against or harassed in the previous 12 months on the basis of a ground of discrimination prohibited under international human rights law. |
| SDG 11: Sustainable Cities and Communities | Target 11.1: By 2030, ensure access for all to adequate, safe, and affordable housing and basic services and upgrade slums. | Indicator 11.1.1: Proportion of urban population living in slums, informal settlements, or inadequate housing. |
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Source: nydailyrecord.com
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