Grieger v. Sheets

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Brief Fact Summary. A woman was sexually harassed, and her husband was threatened, when she refused to give in to her landlord’s sexual demands.

Synopsis of Rule of Law. Sexual harassment violates the Fair Housing Act’s (Act’s) prohibition on sexual discrimination.

Facts. Gina Grieger and Ezekial Carter (Plaintiffs) are husband and wife. Grieger rented a house from Walter Sheets (Defendant), who told them he would repair their house after the lease was signed. Defendant demanded sexual favors from Grieger and threatened that continued tenancy required her compliance. When she refused, he harassed and intimidated Plaintiffs by threatening to shoot Carter, not repairing the house, damaging their property, telling them their lease would not be renewed, and forcing them to get rid of their dog. Plaintiffs allege a violation of the Act.

Issue. Is sexual harassment a violation of the Fair Housing Act?

Held. Yes.
The Act states that it is unlawful to coerce, intimidate, threaten, or interfere with any person in the exercise or enjoyment of, or on account of his having aided or encouraged any other person in the exercise or enjoyment of property rights.
Is Carter’s claim that he was threatened by Defendant as a result of encouraging his wife not to exchange for housing and repairs valid?
Trading sex for tenancy and services is a form of direct discrimination under the statute. After refusing his demands, she was intimidated, threatened or interfered with by Defendant, which also falls under the protection of the Act.

Discussion. Sexual harassment violates the Fair Housing Act’s prohibition of sex discrimination in housing. It seems there has to be several incidents of harassment for a violation to be found.