Published January, 1996

Ryan v. Ramsey, 936 F. Supp. 417 (S.D. Tex. 1996)

Relying on the Seventh Circuit's four-prong impact analysis outlined in Metropolitan Housing Development Corp. v. Village of Arlington Heights, 558 F.2d 1283 (7th Cir. 1977), the District Court found that a landlord's refusal to rent to an HIV-positive applicant receiving disability benefits could be a violation of the FHA. The court asserted that the plaintiff had presented enough evidence to survive summary judgment on the discriminatory intent prong, noting that although the landlord did not necessarily know the applicant had AIDS, she aware that the applicant was receiving government disability benefits. In addition, although there was evidence that the landlord did not discriminate against all people with AIDS , there was still an issue of material fact regarding whether or not she discriminated against disabled persons receiving government benefits.

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