A DC association beat a Fair Housing claim over master-policy repairs
A DC association beat a Fair Housing claim over master-policy repairs
2026-09-09 · District of Columbia · Courts
A District of Columbia condominium association has won summary judgment on a Fair Housing Act claim that it refused to fund repairs for a Black townhome owner while paying for similar repairs for white owners. The decision is a clean illustration of what actually defeats a discrimination claim over master-policy access: bylaws that draw a clear line, and a coverage trigger applied evenly.
Reese v. Park Place Condominium Homeowners Ass'n I, No. 22-cv-02660 (CRC), was decided by Judge Cooper of the U.S. District Court for the District of Columbia on March 21, 2025.1
The claim
The owner alleged that the association declined to fund repairs to her unit, including through its master insurance policy, while funding comparable repairs for white owners. The case was removed from DC Superior Court. An earlier ruling in September 2023 had allowed the race-discrimination claim to proceed and dismissed a retaliation claim.
The claim was brought under 42 U.S.C. § 3605, the Fair Housing Act provision covering residential real-estate-related transactions.
Why it failed
The association put forward a non-discriminatory explanation and the owner did not rebut it.
The explanation had two parts. First, under its bylaws the association is responsible only for damage affecting buildings as a whole — not for damage confined to an individual unit. Second, the association's insurance policy provides coverage for casualty damage, and the owner had not alleged a casualty event.
The court found the owner's inference from insurance loss-run reports unreasonable, noting that “the reports do not identify the units for which any insurance funds were used.” It also observed that the plaintiff's counsel had served no interrogatories, made no document requests, and deposed no witnesses.
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