Violence Against Women Act (VAWA)

A woman filed a complaint against Michigan housing provider, Czapp Real Estate, LLC, alleging that they denied housing to her because of her disability and status as a survivor under the Violence Against Women Act (VAWA). The Complainant alleged that the landlord did not respond to her rental application due to her vision impairment and because she revealed a past tenancy was terminated due to experiencing dating violence and stalking. Under the terms of the Conciliation Agreement, Czapp Real Estate, LLC, will pay the Complainant $8,500. Czapp Real Estate, LLC, will also take affirmative steps to ensure their policies, practices, and procedures comply with VAWA and the Fair Housing Act. The Conciliation Agreement further stipulates that the Czapp Real Estate, LLC, will require all its staff to attend VAWA-related training.

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The Voluntary Agreement stems from a limited compliance review initiated by HUD in November 2022 under Section 504 for Greenbriar Apartments, a 208-unit development in Tennessee owned by Alco Greenbriar Partners, LP, whose general partner is Alco Properties, Inc. The property is managed by Alco Management, Inc., which manages over 50 multifamily properties throughout the Southeast. The property receives Project Based Rental Assistance through HUD Multifamily Housing.

Following the limited compliance review, the Letter of Findings of Noncompliance was issued in April 2023, describing the housing providers’ effective denial of multiple reasonable accommodation or modification requests. HUD also uncovered instances of VAWA noncompliance involving households that experienced incidents of sexual assault and/or domestic violence. Two tenants requested VAWA emergency transfers and in both instances, the housing providers failed to provide the transfer or take any additional action needed to process the requests. Under the Voluntary Conciliation Agreement, the housing providers agree to pay the aggrieved parties $50,000 in monetary compensation. The housing providers will also amend its reasonable accommodation transfer log, revise the transfer policy, revise its VAWA policies, construct or convert ten UFAS-accessible units, with an additional four units for the hearing and visually impaired and accessible common areas, designate a VAWA Coordinator, respond to VAWA-related grievances and transfer requests within ten days, and attend VAWA training.

Read the Conciliation Agreement    VAWA Memo    Letter of Findings

HUD’s investigation found that a tenant who had a Housing Choice Voucher alleged that a Public Housing Agency in Nevada (“PHA”) and its Housing Specialist violated the complainant’s rights under VAWA when the complainant requested to relocate mid-lease as an emergency transfer after being stalked by a former partner. The complainant alleged that the housing provider demanded confusing and contradictory documentation that it was not permitted to request under VAWA, threatened to revoke the complainant’s voucher, denied her request to extend her voucher, and stopped paying its portion of the rent while the complainant prepared to move to protect her safety. HUD’s investigation indicated that the PHA’s policies and procedures did not comply with VAWA, including policies for documenting someone’s status as a VAWA survivor in general and, specifically, when an emergency transfer is requested. The PHA also lacked an emergency transfer plan, as required by VAWA. The agreement requires the housing provider to adopt and implement policies that comply with VAWA and will protect the VAWA rights of its applicants and residents, including that the PHA has an Emergency Transfer Plan that will allow survivors who qualify to move quickly without losing their assistance, to hire outside experts to provide VAWA training to staff, and to pay the complainant a monetary settlement.

A woman filed a complaint alleging that a housing management company in CA, which is a recipient of funds under the HOME Investment Partnerships Program (“HOME”) and Low-Income Housing Tax Credits (“LIHTC”), and a property manager violated her rights under VAWA by denying her application due to a history of violations of the terms of previous rental agreements that were related to her status as a survivor of dating violence. Although the housing providers denied that the tenant disclosed her status as a dating violence survivor, they acknowledged that they failed to accompany the denial letter with any information about her rights under VAWA, as required by law, and that they did not advise her about how she might appeal the denial. Under the terms of the agreement, the housing providers will pay the complainant a monetary settlement, place her on the top of the waitlist for the next available unit at two properties, notify her in writing when such a unit becomes available, revise their policies and procedures to comply with VAWA and protect the VAWA rights of applicants and tenants, establish a VAWA Rights Coordinator to handle VAWA matters and compliance, and require their employees to complete VAWA training annually.

HUD-subsidized housing provider refused to renew a domestic violence survivor’s lease based on 911 calls made to report domestic violence. Housing provider agreed to pay $11,250 to the survivor, attend fair housing training, keep a record of vacancies and all rental applications (including reasons for rejection), modify lease and renewal procedures, and cooperate with HUD in future fair housing monitoring.

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Housing provider refused to rent a unit to the survivor because of past visits to her apartment from the police relating to domestic violence. Housing provider agreed to pay $2,300 to the survivor, attend fair housing training, keep a record of all rental applications (including reasons for denial), and cooperate with HUD in future fair housing monitoring.

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Housing provider refused to rent a unit to the survivor because she would not disclose her children’s Social Security Numbers due to domestic violence safety and privacy concerns. Housing provider agreed to pay $20,000 to the survivor, accept truncated Social Security Numbers, provide points of contact for housing availability, revise its policy to include VAWA protections and allow VAWA accommodations, allow those who were illegally denied housing due to VAWA protections to re-apply, display a HUD fair housing poster in the rental office, provide VAWA and fair housing training to staff, and cooperate with HUD in future fair housing monitoring.

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A domestic violence survivor was not allowed to testify during a hearing to remove her abuser from the lease. The housing authority agreed to issue a Notice of Proposed Decision to Terminate Assistance to the abuser and call complainant as a witness if a hearing was to be held, allow survivors to testify at future lease bifurcation hearings, and cooperate with HUD in future fair housing monitoring.

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A local ordinance (referred to as the “Three Strikes Ordinance”) punished survivors each time police were called for domestic violence protection and forced their landlords to evict them under the guise of “disorderly conduct.” The City of Norristown was required to: provide a copy of the Conciliation Agreement with employees and retain a copy for public review; provide fair housing training to City staff and anyone interacting with victims of domestic violence; develop an education program and brochure regarding rights under the Fair Housing Act; repeal the Three Strikes Ordinance; partner with local anti-domestic violence advocates to raise awareness about domestic violence through a community service activity and conduct such activity annually; report housing discrimination complaints annually to HUD; and cooperate with HUD in future fair housing monitoring.

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A domestic violence survivor had her lease terminated by a private landlord participating in the Housing Choice Voucher program after survivor was attacked by her boyfriend in her unit, whereas a male tenant did not suffer similar consequences when his son assaulted residents in the complex. As a result of these facts, HUD issued a charge of discrimination against the housing provider.

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A USDA-subsidized housing provider issued a survivor an eviction notice after she was physically attacked by her husband in the unit, and later denied her application for a new unit based on the domestic violence incident. There was a finding of reasonable cause that the housing provider discriminated against the survivor based on her sex.

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Complaint based on unlawful enforcement of an ordinance requiring landlords to evict tenants with at least three “disorderly behavior” incidents or risk losing their rental license and/or be subject to fines. This ordinance had a disproportionate effect on female survivors of domestic violence. The City agreed to change the ordinance to exempt victims of domestic violence; provide training to City staff and anyone interacting with victims of domestic violence; partner with a local domestic violence advocacy group to raise awareness about domestic violence; report housing discrimination complaints annually; cooperate with HUD in future fair housing monitoring.

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