Friday, June 5, 2009

10% Discount on Michigan Real Estate Continuing Education

We are offering a 10% discount on the purchase of all of our online Michigan real estate continuing education courses. Simply type blogger10 in the "Discount Code" field at the top of the checkout page. You must purchase your courses by June 30, 2009 to take advantage of this offer. Even though you need to purchase the courses by that date to take advantage of the discount, you can take the courses for up to one year after the purchase date. Please feel free to share that discount code with your friends and colleagues.

ACT NOW!! Don't forget that all licensed Michigan real estate professionals must complete 18 credit hours of continuing education by October 31, 2009, in order to renew their licenses. Don't wait to the last minute to get this done. All of our courses are fully approved and certified by the State of Michigan, and we offer one of the cheapest prices out there. Even without the 10% discount, we offer 6 credits for only $35!

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www.123ConEd.com offers a simple, convenient and easy way to get your credits.

  • Classes are 100% online, so take classes wherever there is an Internet connection
  • Work at your own pace (start/stop whenever you want)
  • Complete a few hours or all of your required hours at once
  • We offer courses in 2, 3, 4 and 6 hour increments, so you can pick topics that interest you
  • Our online courses are a fraction of the cost of a live class
  • All courses are fully approved and certified by the State of Michigan
  • Completion Certificate automatically generated as soon as you complete course

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Tuesday, June 2, 2009

Attorney Sentenced to 5 Years in Prison in Mortgage Loan Fraud Scheme

justice

Here is another example of a recent legal case involving a fraudulent real estate scheme committed by a real estate agent. I try to post case summaries in order to provide timely updates to real estate professionals on important issues.

On May 11, 2009, John A. Yanchek was sentenced to 60 months in prison and ordered to forfeit $7.6 million for conspiracy to commit loan fraud, bank fraud, and money laundering.

According to court documents, Mr. Yanchek was a licensed Florida attorney who did business as the law firm of John A. Yanchek, P.A., in Sarasota, Florida. Mr. Yanchek represented G & T Land Development LLC and Steeplechase Properties LLC, legal entities owned and/or controlled by his co-conspirators, that purchased and developed commercial real estate in the Sarasota area. Mr. Yanchek also functioned as a closing agent.

According to the plea agreement, Mr. Yanchek entered into a conspiracy to make false statements to federally-insured banks in connection with applications for commercial loans used to purchase vacant land for development. The object of the conspiracy was to obtain enough loan money to allow the conspirators to purchase the property without contributing any equity of their own and to receive excess loan proceeds for their personal use. Mr. Yanchek, as the closing attorney for the loans, made false statements to the banks regarding: (1) the financial resources of the borrower, (2) the amount and source of equity contributed by the borrower, (3) compliance with the seller's obligation to provide marketable title to the property, and (4) distribution of the loan proceeds.

Co-defendant Larry P. Nardelli was convicted on February 19, 2009, and is awaiting sentencing. Michael A. Tringali pleaded guilty and received a 41 month prison sentence. The third co-defendant Neil M. Husani remains a fugitive.

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To learn more about a variety of real estate topics, please visit us at www.123ConEd.com. We are the leading online provider of Michigan real estate continuing education. All of our courses are fully approved and properly certified by the State of Michigan, and are offered online.

Copyright © 123 ConEd LLC 2009. All rights reserved.

Real Estate Agent Sentenced to 46 Months in Prison in Scheme to Defraud Mortgage Lenders

justice

Here is another example of a recent legal case involving a fraudulent real estate scheme committed by a real estate agent. I try to post case summaries in order to provide timely updates to real estate professionals on important issues.

On May 11, 2009, Oladipo Olafunmiloye, a real estate agent, was sentenced to 46 months in prison, to be followed by five years of supervised release, for bank fraud and money laundering in connection with a scheme to defraud mortgage lenders. At the sentencing, the judge found that Mr. Olafunmiloye’s fraudulent scheme incurred losses of $3 million and ordered him to pay restitution in that amount, as well as forfeit his interest in a Rolls Royce automobile and funds held in four bank accounts.

According to his plea agreement, Mr. Olafunmiloye owned a real estate company known as LAFA. From November 2004 to December 2006, Mr. Olafunmiloye organized a scheme in which co-defendants Sidney Okosun, Oyekunle Ikudayisi, Kolawole Aminu and others sought to fraudulently obtain mortgages and refinance loans to purchase properties for sale in Maryland and the District of Columbia that were owned by Mr. Olafunmiloye or LAFA. The defendants recruited individuals to act as purchasers who became owners of the properties in name only and made almost none of the payments related to the purchase of the properties, including down payments, closing costs and mortgage payments

Mr. Olafunmiloye supervised the submission of false statements on loan applications as to the straw buyers’ incomes and their intent to make the properties their primary residences, in order to induce mortgage lenders to make loans at more favorable rates. Mr. Olafunmiloye also provided capital to the other defendants in order to perpetuate the scheme. Once the purchase of the properties had been funded, Mr. Olafunmiloye defaulted on mortgage payments, which forced the lenders to foreclose, thereby incurring losses.

During the course of the scheme, Mr. Olafunmiloye also provided false information to obtain loans in his own name, including loans on five properties, all of which went into foreclosure, resulting in losses to the mortgage lenders of over $492,767. Finally, Mr. Olafunmiloye laundered money obtained from the fraud scheme, including 12 transactions from August 2005 to September 2006 totaling $308,311.

It’s amazing what some people will do to make money.

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To learn more about a variety of real estate topics, please visit us at www.123ConEd.com. We are the leading online provider of Michigan real estate continuing education. All of our courses are fully approved and properly certified by the State of Michigan, and are offered online.

Copyright © 123 ConEd LLC 2009. All rights reserved.

A Few Examples of Illegal Housing Practices Against Persons with Disabilities Under the Fair Housing Act

fair housing

Here is a little reminder for everyone about their obligations under the Fair Housing act with respect to people with disabilities. The following are a few examples of illegal housing practices against persons with disabilities under the Fair Housing Act:

  • Refusing to rent or sell or otherwise making unavailable to an individual with a disability a dwelling unit, because of the buyer’s or renter’s disability;
  • Imposing different terms and conditions on the sale or rental of a dwelling unit due to the buyer’s or renter’s disability;
  • Coercing, intimidating or threatening a person for exercising his or her rights under the Fair Housing Act;
  • Informing an individual with a disability that a dwelling was not available for inspection, when in fact the dwelling was available;
  • Discriminating against any person who associates with a person with a disability in the sale or rental of a covered dwelling unit;
  • Blockbusting – that is paying someone to rent or sell a dwelling unit to another person, so as to prevent an individual with a disability from moving into a neighborhood;
  • Refusing to make reasonable accommodations of rules, policies, practices or services that are needed to accommodate an individual with a disability;
  • Refusing to allow a tenant with a disability to undertake reasonable structural modifications to an existing building which may be necessary to accommodate that person’s disability;
  • Engaging in any real estate-related transaction that promotes discrimination against an individual with a disability;
  • Denying a person with a disability access to a multiple listing service, real estate broker’s organization or other related service based upon his or her disability;
  • Asking a prospective tenant/home-buyer about his or her disability;
  • Requiring tenants or others living in housing to be able to “live independently”;
  • Requiring a person with a disability to pay a higher security deposit than that requested from a tenant without a disability;
  • Publishing an advertisement, notice or statement which limits or excludes individuals with disabilities from renting or purchasing a dwelling;
  • Denying housing due to a present or past history of a mental illness;
  • Asking a prospective tenant about illegal drug use or illegal drug convictions unless those questions are asked of all prospective tenants.

It is important for all real estate professionals to remember that the federal Fair Housing Act prohibits discrimination in housing on the basis of race, color, religion, sex, familial status, national origin and disability.

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To learn more about fair housing issues (and many other real estate topics), please visit us at www.123ConEd.com. We are the leading online provider of Michigan real estate continuing education. All of our courses are fully approved and properly certified by the State of Michigan, and are offered online.

Copyright © 123 ConEd LLC 2009. All rights reserved.

Types of Discrimination Against Persons with Disabilities Prohibited by the Fair Housing Act

housing

The goal of the Fair Housing Act is to ensure “no person shall be subjected to discrimination because of race, color, religion, sex, handicap, familial status or national origin in the sale, rental or advertising of dwellings, in the provision of brokerage services, or in the availability of residential real-estate related transactions.” With respect to people with disabilities, the Act serves to:

  • Give people with disabilities opportunities to choose where they want to live;
  • Assure that reasonable accommodations and reasonable modifications are made so that a person with a disability can secure and use housing as fully as a person without a disability.
  • Assure that persons with disabilities are able to live free from intimidation and harassment; and
  • Require that multi-family housing built for first occupancy after March 13, 1991, has certain accessible features (e.g., a usable kitchen for a person who uses a wheelchair).

The Fair Housing Act prohibits housing providers from discriminating against applicants or residents because of their disability or the disability of anyone associated with them and from treating persons with disabilities less favorably than others because of their disability. The Act also prohibits housing providers from refusing residency to persons with disabilities, or, with some narrow exceptions, placing conditions on their residency, because those persons may require reasonable modifications or reasonable accommodations.

With respect to reasonable accommodations and reasonable modifications:

  • The Act makes it unlawful for any person to refuse “to make reasonable accommodations in rules, policies, practices, or services, when such accommodations may be necessary to afford . . . person(s) [with disabilities] equal opportunity to use and enjoy a dwelling.”
  • The Act makes it unlawful for any person to refuse “to permit, at the expense of the [disabled] person, reasonable modifications of existing premises occupied or to be occupied by such person if such modifications may be necessary to afford such person full enjoyment of the premises, except that, in the case of a rental, the landlord may where it is reasonable to do so condition permission for a modification on the renter agreeing to restore the interior of the premises to the condition that existed before the modification, reasonable wear and tear excepted.”

It is important for all real estate professionals to remember that the federal Fair Housing Act prohibits discrimination in housing on the basis of race, color, religion, sex, familial status, national origin and disability.

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To learn more about fair housing issues (and many other real estate topics), please visit us at www.123ConEd.com. We are the leading online provider of Michigan real estate continuing education. All of our courses are fully approved and properly certified by the State of Michigan, and are offered online.

Copyright © 123 ConEd LLC 2009. All rights reserved.

Rules About When/How a Tenant Must Request a Reasonable Accommodation or Permission to Make a Reasonable Modification

fair housing

Under the Fair Housing Act, a resident or an applicant for housing makes a reasonable accommodation request whenever she makes clear to the housing provider that she is requesting an exception, change, or adjustment to a rule, policy, practice, or service because of her disability. She should explain what type of accommodation she is requesting and, if the need for the accommodation is not readily apparent or not known to the provider, explain the relationship between the requested accommodation and her disability.

Similarly, a resident or an applicant for housing makes a reasonable modification request whenever she makes clear to the housing provider that she is requesting permission to make a structural change to the premises because of her disability. She should explain that she has a disability, if not readily apparent or not known to the housing provider, the type of modification she is requesting, and the relationship between the requested modification and her disability.

An applicant or resident is not entitled to receive a reasonable accommodation or modification unless she requests one. However, the Fair Housing Act does not require that a request be made in a particular manner or at a particular time. A person with a disability need not personally make the reasonable accommodation request; the request can be made by a family member or someone else who is acting on her behalf. An individual making a reasonable accommodation or modification request does not need to mention the Act or use the words “reasonable accommodation” or “reasonable modification.” However, the requester must make the request in a manner that a reasonable person would understand to be a request for an exception, change, or adjustment to a rule, policy, practice, or service because of a disability or that a reasonable person would understand to be a request for permission to make a structural change because of a disability.

Although a reasonable accommodation or modification request can be made orally or in writing, it is usually helpful for both the resident and the housing provider if the request is made in writing. This will help prevent misunderstandings regarding what is being requested, or whether the request was made. To facilitate the processing and consideration of the request, residents or prospective residents may wish to check with a housing provider in advance to determine if the provider has a preference regarding the manner in which the request is made. However, housing providers must give appropriate consideration to reasonable accommodation and modification requests even if the requester makes the request orally or does not use the provider’s preferred forms or procedures for making such requests.

Example: A tenant in a large apartment building makes an oral request that she be assigned a mailbox in a location that she can easily access because of a physical disability that limits her ability to reach and bend. The provider would prefer that the tenant make the accommodation request on a pre-printed form, but the tenant fails to complete the form. The provider must consider the reasonable accommodation request even though the tenant would not use the provider’s designated form.

It is important for all real estate professionals to remember that the federal Fair Housing Act prohibits discrimination in housing on the basis of race, color, religion, sex, familial status, national origin and disability.

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To learn more about fair housing issues (and many other topics affecting real estate professionals), please visit us at www.123ConEd.com. 123 ConEd LLC (www.123ConEd.com) is a leading online provider of continuing education courses to real estate professionals in Michigan. Our online real estate con ed courses are fully approved and properly certified by the Michigan Department of Labor & Economic Growth. All of our courses are designed to offer our students the most information, as quickly and economically as possible.

Copyright © 123 ConEd LLC 2009. All rights reserved.

When does a housing provider know that a reasonable accommodation is needed?

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The duty to accommodate arises only when the housing provider has knowledge that a disability exists and that an accommodation may be required for the disabled person to use and enjoy the housing. Here are key points:

  • The applicant or resident must make a request for an accommodation.
  • The request does not need to mention fair housing or use the words “reasonable accommodation.”
  • The request should describe the accommodation and explain the disability-related need for the requested action. For example: A resident who becomes disabled may request a transfer to a ground floor apartment because climbing the stairs has become difficult.
  • The request does not need to be in writing. Although management may use a specific form, an accommodation cannot be refused just because the person requesting it did not use the form. It is important for management to document these requests.
  • Reasonable accommodations can be requested whenever they are needed. A person may make requests when applying for housing, when entering into a rental agreement, during tenancy, and even during an eviction process.
  • An individual with a disability may make multiple requests for accommodations, as the need arises.

The housing provider must evaluate each request on a case-by-case basis, in a timely and professional manner, and should document interactions with the resident. A housing provider has an obligation to provide prompt responses to reasonable accommodation requests. An undue delay in responding to a request may be considered to be a failure to provide a reasonable accommodation. If in doubt about whether accommodation policies and rules comply with fair housing laws, ask a fair housing agency to review them and suggest rephrasing if necessary.

A housing provider is not obligated to provide a reasonable accommodation to a resident or applicant if an accommodation has not been requested. A provider has notice that a reasonable accommodation request has been made if a person, her family member, or someone acting on her behalf requests a change, exception, or adjustment to a rule, policy, practice, or service because of a disability, even if the words “reasonable accommodation” are not used as part of the request.

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To learn more about fair housing issues (and many other topics affecting real estate professionals), please visit us at www.123ConEd.com. 123 ConEd LLC (www.123ConEd.com) is a leading online provider of continuing education courses to real estate professionals in Michigan. Our online Michigan real estate con ed courses are fully approved and properly certified by the Michigan Department of Labor & Economic Growth. All of our courses are designed to offer our students the most information, as quickly and economically as possible.

Copyright © 123 ConEd LLC 2009. All rights reserved.

Radon Health Risks

radon

Radon gas is a naturally occurring radioactive gas that is invisible and odorless. It forms from the radioactive decay of small amounts of uranium and thorium naturally present in rocks and soils so some radon exists in all rocks and soils. Because radon is a gas, it can easily move through soil and cracks in building slabs or basement walls and concentrate in a building’s indoor air. The U.S. Surgeon General and the EPA recommend that all homes in the United States be tested for radon.

Radon is a Class A carcinogen, which means it is known to cause cancer in humans. Most people do not know that radon is the second leading cause of lung cancer in the United States, resulting in approximately 21,000 lung cancer deaths each year. Only smoking causes more lung cancers.

The problem occurs when radon and radon decay products ("RDPs") are breathed in. Radon is exhaled, as are many of the RDPs, but some of the RDPs get trapped in the lungs. As they undergo radioactive decay and emit alpha energy, the alpha particles can strike sensitive lung tissue, causing physical and/or chemical damage to the DNA. When alpha particles strike and damage a lung cell, the cell will either:

  • Die (which seems like a bad thing, but new cells are generated to replace dead cells)
  • Repair itself and heal
  • Try to repair itself, but do so incorrectly. Eventually, this can lead to the formation of cancerous cells.

Not everyone who breathes radon will develop lung cancer. Your risk is determined by such things as:

  • How much radon is in your indoor environment.
  • The amount of time you spend in that indoor environment.
  • Whether you smoke or ever have smoked.

The only known health effect of radon is an increased risk of lung cancer, and exposure to elevated radon levels does not result in any warning symptoms like headaches, nausea, fatigue, or skin rashes. The only way to know whether you are being exposed to elevated radon levels is to test your home (and other indoor environments).

Many national and international organizations believe radon is an important environmental health concern, and they support testing for radon and reducing exposure to elevated radon levels. Just a few of those organizations are listed below:

  • American Lung Association
  • American Medical Association
  • Centers for Disease Control
  • Environmental Protection Agency
  • International Commission on Radiological Protection
  • National Academy of Science
  • National Council on Radiation Protection and Measurement
  • U.S. Surgeon General
  • Health Organization

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We offer online real estate continuing education to Michigan agents and brokers. We offer numerous different course titles on our easy to use and easy to navigate website (www.123ConEd.com). All of our courses have been approved and certified by the State of Michigan.

Copyright © 123 ConEd LLC 2009. All rights reserved.

Radon Myths and Facts

Radon

There are a lot of misconceptions about radon with respect to homes and real estate. Here are a few of the most common radon-related myths and the true facts.

MYTH: Scientists are not sure that radon really is a problem.

FACT: Although some scientists dispute the precise number of deaths due to radon, all the major health organizations (like the Centers for Disease Control and Prevention, the American Lung Association and the American Medical Association) agree with estimates that radon causes thousands of preventable lung cancer deaths every year. This is especially true among smokers, since the risk to smokers is much greater than to non-smokers. According to the EPA, the are over 21,000 radon-related deaths in the United States each year.

MYTH: Radon testing is difficult, time-consuming and expensive.

FACT: Radon testing is easy. You can test your home yourself or hire a qualified radon test company. Either approach takes only a small amount of time and effort.

MYTH: Radon testing devices are not reliable and are difficult to find.

FACT: Reliable testing devices are available from qualified radon testers and companies. Reliable testing devices are also available by phone or mail-order, and can be purchased in hardware stores and other retail outlets. Call your state radon office for help in identifying radon testing companies.

MYTH: Homes with radon problems can't be fixed.

FACT: There are simple solutions to radon problems in homes. Hundreds of thousands of homeowners have already fixed radon problems in their homes. According to the EPA, radon levels can be readily lowered for $800 to $2,500 (with an average cost of $1,200). Call your state radon office for help in identifying qualified mitigation contractors.

MYTH: Radon affects only certain kinds of homes.

FACT: House construction can affect radon levels. However, radon can be a problem in homes of all types: old homes, new homes, drafty homes, insulated homes, homes with basements, and homes without basements. Local geology, construction materials, and how the home was built are among the factors that can affect radon levels in homes. The only way to tell if a specific home has elevated levels of radon is to test.

MYTH: Radon is only a problem in certain parts of the country.

FACT: High radon levels have been found in every state. Radon problems do vary from area to area, but the only way to know your radon level is to test.

MYTH: A neighbor's test result is a good indication of whether your home has a problem.

FACT: It's not. Radon levels can vary greatly from home to home. The only way to know if your home has a radon problem is to test it.

MYTH: Everyone should test their water for radon.

FACT: Although radon gets into some homes through water, it is important to first test the air in the home for radon. If your water comes from a public water supply that uses ground water, call your water supplier. If high radon levels are found and the home has a private well, call the Safe Drinking Water Hotline at 1-800-426-4791 for information on testing your water.

MYTH: It's difficult to sell homes where radon problems have been discovered.

FACT: Where radon problems have been fixed, home sales have not been blocked or frustrated. The added protection is sometimes a good selling point.

MYTH: I've lived in my home for so long, it doesn't make sense to take action now.

FACT: You will reduce your risk of lung cancer when you reduce radon levels, even if you've lived with a radon problem for a long time.

MYTH: Short-term tests can't be used for making a decision about whether to fix your home.

FACT: A short-term test, followed by a second short-term test, can be used to decide whether to fix your home. However, the closer the average of your two short-term tests is to 4 pCi/L, the less certain you can be about whether your year-round average is above or below that level. Keep in mind that radon levels below 4 pCi/L still pose some risk. Radon levels can be reduced in most homes to 2 pCi/L or below.

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123 ConEd LLC offers online real estate continuing education to Michigan agents and brokers. We offer numerous different course titles on our easy to use and easy to navigate website (www.123ConEd.com). All of our courses have been approved and certified by the State of Michigan.

Copyright © 123 ConEd LLC 2009. All rights reserved.

Fair Housing Lawsuit Settled for $130,000 + Retrofitting Costs

scalesHere is another example of a recent settlement of a Fair Housing Act lawsuit brought by the United States Department of Justice (“DOJ”). I try to post case summaries in order to provide timely updates to real estate agents and brokers about the "dos and don'ts" under the Fair Housing Act, since fair housing is such an important issue.

Yesterday afternoon (Wednesday, May 20, 2009), the DOJ settled a Fair Housing Act lawsuit that was brought against the developers, architects, and professional engineers responsible for building four multifamily housing complexes in Spokane, Washington. The lawsuit alleged that the defendants designed and built the complexes in violation of the Fair Housing Act by failing to make the complexes accessible to wheelchair users and other persons with physical disabilities.

According to the lawsuit, the defendants each designed portions of one or more of the complexes without including required accessibility features in the designs. Since 1989, federal law has required that new multifamily housing contain certain features to make it accessible to and usable by wheelchair users and other persons with physical disabilities.

Under the terms of the settlement, the defendants will pay all costs related to making the apartment complexes accessible to persons with disabilities and will pay $120,000 to compensate individuals harmed by the inaccessible housing. The developer will pay a $10,000 civil penalty to vindicate the public interest and most of the defendants will undergo training on the requirements of the Fair Housing Act.

The retrofitting includes modifying walkways to eliminate excess slopes and level changes, providing accessible curb ramps, and parking and routes to site amenities, such as clubhouses, pools, mailboxes and trash facilities. The settlement also provides for the replacement of inaccessible knob door hardware with levers, the widening of inaccessible doorways, and the reconfiguration of bathrooms and kitchens to accommodate persons who use wheelchairs.

As all real estate professionals should already know, the Fair Housing Act prohibits discrimination in housing based on race, color, religion, national origin, sex, disability and familial status. Among other things, the Act requires that new multifamily housing development be designed and constructed with basic accessibility features, including accessible common and public use areas, accessible routes to and through apartments, doors wide enough for wheelchair users, kitchens and bathrooms with sufficient maneuvering space for wheelchair users, outlets and environmental controls in accessible locations and bathrooms with reinforcements for grab bars.

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To learn more about fair housing issues (and many other real estate topics), please visit us at www.123ConEd.com. We are the leading online provider of Michigan real estate continuing education. All of our courses are fully approved and properly certified by the State of Michigan, and are offered online.

Copyright © 123 ConEd LLC 2009. All rights reserved.

Fair Housing Lawsuit Filed Against Town

scalesHere is another example of a recent Fair Housing Act lawsuit brought by the United States Department of Justice (“DOJ”). I try to post case summaries in order to provide timely updates to real estate agents and brokers about the "dos and don'ts" under the Fair Housing Act, since fair housing is such an important issue.

Yesterday afternoon (Tuesday, May 19, 2009), the DOJ filed a Fair Housing Act lawsuit against the town of Garner, North Carolina, and the town’s board of adjustment alleging that they violated the Fair Housing Act when they refused to allow up to eight men recovering from drug and alcohol addictions to live together as a reasonable accommodation for their disabilities.

The lawsuit also alleges that the defendants had engaged in a denial of rights to a group of persons or a pattern or practice of discrimination by failing or refusing to recognize their obligation to make reasonable accommodations. The home is chartered by Oxford House Inc., a non-profit organization that assists in the development of self-governing houses in which persons in recovery support one another’s determination to remain sober. The town of Garner permits up to six persons to live in the home, but has refused to consider requests by Oxford House to increase the number to eight.

The Fair Housing Act requires jurisdictions to make reasonable accommodations in their rules when necessary to provide persons with disabilities an equal opportunity to housing. As a result, the DOJ believes that the town should have granted the request to allow eight people as a reasonable accommodation.

This case arose as a result of a complaint filed with HUD by Oxford House. HUD conducted an investigation and referred the matter to the DOJ.

The lawsuit seeks monetary damages for the victims, a civil penalty and a court order requiring Garner to grant the requested accommodation and establish a procedure for considering future accommodation requests. The complaint is an allegation of unlawful conduct. The allegations must still be proven in federal court.

I will try to follow this case and provide an update when the case is resolved.

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To learn more about fair housing issues (and many other real estate topics), please visit us at www.123ConEd.com. We are the leading online provider of Michigan real estate continuing education. All of our courses are fully approved and properly certified by the State of Michigan, and are offered online.

Copyright © 123 ConEd LLC 2009. All rights reserved.