## Facts

- A landlord, Walter Case, advertised an apartment for rent in New Orleans.
- Lisa Lincoln (Japanese-American) and Don Weaver (African-American), an interracial couple, sought to rent the apartment.
- Case told them the apartment was unavailable, claiming it had been rented to his daughter.
- A fair housing organization arranged four testers (two white, two Black) to inquire about the apartment.
- Case told both Black testers the apartment was unavailable, but told both white testers it was available.
- Lincoln and Weaver sued under the Fair Housing Act (FHA), alleging intentional race discrimination in the refusal to rent.
- A jury found Case acted maliciously and awarded Weaver $500 in compensatory damages and $100,000 in punitive damages; Lincoln received no damages.
- The district court denied Case’s post-trial motions for judgment as a matter of law and for remittitur, and Case appealed.

## Issues

1. Whether the FHA applied, or whether the property fell within an FHA statutory exemption such that federal subject-matter jurisdiction was lacking.
2. Whether Weaver had standing as an “aggrieved person” under the FHA despite not obtaining the apartment or showing substantial economic loss.
3. Whether the $100,000 punitive damages award, compared to $500 compensatory damages, was unconstitutionally excessive under due process limits.

## Decision

- The Fifth Circuit held the FHA applied and rejected Case’s claimed exemption defense.
- The court held Weaver had standing under the FHA as an “aggrieved person” based on injury from discriminatory housing practices, including dignitary and emotional harms.
- The court upheld the availability of punitive damages given the jury’s finding of malicious discrimination.
- The court held the $100,000 punitive award was excessive under due process and ordered remittitur to $55,000 (or a new trial limited to punitive damages if not accepted).

## Legal Principles

- FHA exemptions are construed narrowly, and the defendant bears the burden to prove entitlement to an exemption.
- Standing under the FHA extends broadly to persons injured by discriminatory housing practices, including non-economic harms such as humiliation and emotional distress.
- Punitive damages may be awarded for reckless or callous indifference to federally protected rights in FHA cases.
- Due process limits punitive damages; courts evaluate excessiveness using the guideposts of reprehensibility, the ratio between punitive and compensatory damages, and comparable civil or criminal sanctions.

## Conclusion

The Fifth Circuit sustained the FHA judgment on coverage and standing and affirmed that intentional racial discrimination in housing can warrant punitive damages, but it reduced the punitive award to satisfy constitutional due process limits.


Lincoln v. Case, 340 F.3d 283 (5th Cir. 2003)