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Judicial Trends Addressing Chronic Conditions

Klossner v. IADU Table Mound MHP, LLC


(U.S. Court of Appeals, 8th Cir., Apr. 10, 2023): The Eighth Circuit held that landlords are not required to accept housing vouchers as a reasonable accommodation for low-income disabled tenants under the Fair Housing Amendments Act (FHAA). The FHAA requires that landlords make reasonable accommodations for tenants’ disabilities. Federal law does not require landlords to accept housing vouchers, though some states prohibit source of income discrimination against tenants. Klossner, a tenant in an Iowa mobile home park, is disabled and receives certain government supports. As Klossner’s rent increased, she sought to use housing vouchers to cover the additional rent. The mobile home park owner refused to accept the vouchers, consistent with their policy of only accepting vouchers when required by state law; Iowa law does not require landlords to accept vouchers. The court held that a landlord’s obligation under the FHAA to make reasonable accommodations includes only those that directly ameliorate disabilities and does not include an obligation to accommodate a tenant’s lack of money. Read the full decision here.

View all cases in Judicial Trends and Public Health – May 16, 2023

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