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TOWN OF HIGHLAND BEACH
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'g'' MINUTES OF THE
BOARD OF ADJUSTMENTS & APPEALS
REGULAR MEETING
Wednesday, May 15, 2013 2.00 PM
Members Present: Chair David Stern, Vice Chair Ruth Samuels, Board Member Barry
Axelrod, Board Member Barry Donaldson, Board Member Evelyn Weiss and Board
Member Bryan Perilman. Also Attending: Town Attorney Len Rubin, Building
Official Michael Desorcy, Deputy Town Clerk Valerie Oakes, Administrative Assistant
Rosalie DeMartino and members of the public.
CALL TO ORDER
Chair Stern called the Regular Meeting to order at 2:00 PM. Roll call was taken by the
Deputy Town Clerk Oakes followed by the Pledge of Allegiance.
INSPECTION'
The Board of Adjustment and Appeals, as part of the public meeting, conducted a site
inspection of the property located at 4210 S. Ocean Blvd., Unit 3, Highland Beach. All
members of the public and interested parties were invited to attend the site inspection.
Site Visit Discussion:
James Paine (representing petitioner Jordan Huffer) — We are planning to extend the side
of the building by 12 feet where the code allows eight feet. The reason is that the eight
foot is so narrow it becomes a glorified hallway. Mr. Huffer has a mother who is
handicapped and we are looking to create a handicapped bathroom and a place on the
ground floor for her to stay. We are willing to landscape as much as the residents to the
north want. (Mr. Paine described the proposed landscaping.)
Norman Weinstein, 4207 Tranquilit y Drive — Is the outer limit of the outside wall going
to be at 12 feet? James Paine — Yes it is. Norman Weinstein — Will the roof structure
extend beyond the 12 feet? James Paine — The roof structure would overhang
approximately two feet beyond the 12 feet; the goal being to match those roofs.
Fred Capacchione, 4206 S. Ocean Blvd — My apartment is on the first floor and there
isn't enough room between the two buildings as it is. If you come out 12 feet, there
won't be much room at all. I don't want to create any hardship to Jordan or his mother,
but I have to look at it every morning when I look out my kitchen window.
Vice Chair Samuels — Regarding the air conditioner area, what did you mean when you
said you were going to clean it up? James Paine — We will move the units about three
feet to the east and then build a wall four feet high or five feet, if necessary, so the
garbage cans and the air conditioners will be better screened. We are also planning to
Board of Adjustment & Appeals Regular Meeting
Wednesday, May 15, 2013 Page 2 of 7
plant shrubs in front of the wall, or any type of vegetation the neighbors to the north
would like.
Member Weiss — What is the code for the wall height? Building Official Desorcy The
code allows for the wall to be at a maximum of six feet.
Member Perilman — Will the 12 feet go to the end of the screened porch? James Paine —
Yes it will.
Joseph Frost, 4210 S. Ocean Blvd. Unit #2 — If the air conditioning unit is moved, will it
be moved directly in front of the electrical units. Will the electrical units be moved, or
will the air conditioning units have to be moved away from the wall? James Paine — We
may have to move the air conditioner further from the wall because I don't believe they
can be directly in front of the electrical units; but in any case, it will be behind the new
screen wall which could be four, five or six feet.
Norman Weinstein — What is the height of the structure? James Paine — The height of the
structure to the underside of the beam is about nine feet. We will have a roof which is
another three to four feet, and that will bring it to about 13 feet. It is a one -story addition.
John Ronco — 4206 S. Ocean Blvd. Unit #2 — The Department of Transportation (DOT) is
going to run a line on the easement which will come from AIA to our seawall to alleviate
the water. They are going to maintain that 18 inch pipe.
The Board and all those present walked over to the south side of the building to view the
addition constructed on Unit #1 which met the eight foot setback.
Vice Chair Samuels — What is this addition used for? Jordan Huffer — It is used as a
television room because it is too narrow to make it any other type of room.
RECONVENE MEETING:
Chair Stern reconvened the meeting and called on the Deputy Town Clerk for a roll call.
Members Present: Chair David Stern, Vice Chair Ruth Samuels, Board Member Barry
Axelrod, Board Member Barry Donaldson, Board Member Evelyn Weiss and Board
Member Bryan Perilman. Also Present: Town Attorney Len Rubin, Building Official
Michael Desorcy, Deputy Town Clerk Valerie Oakes and members of the public.
ADDITIONS, DELETIONS OR ACCEPTANCE OF AGENDA
Chair Stern called for any additions or deletions to the agenda, hearing none, called for a
motion to accept the agenda.
MOTION: Vice Chair Samuels moved to accept the agenda as presented. Member
Weiss seconded the motion, which passed unanimously.
Board of Adjustment & Appeals Regular Meeting
Wednesday, May 15, 2013 Page 3 of 7
PUBLIC COMMENTS AND REOUESTS:
No public comments or requests.
PRESENTATIONS:
No presentations. Chair Stern welcomed Bryan Perilman as the newest Board Member.
APPROVAL OF MINUTES:
• March 6, 2013 — Special Meeting
Chair Stern called for a motion to approve the minutes from the March 6, 2013, Special
Meeting.
MOTION: Member Axelrod moved to approve the minutes from the March 6, 2013
Special Meeting. Member Weiss seconded the motion, which passed unanimously.
OLD BUSINESS:
No old business.
NEW BUSINESS:
Chair Stern closed the regular meeting at 2:31 PM. By consensus, the Board agreed to
close the regular meeting.
• Variance Request: 4210 South Ocean Blvd. — Public Hearing
Application No. 29605 — RELIEF FROM HIGHLAND BEACH CODE OF
ORDINANCES SECTION 30 -64, TABLE 30 -2, THAT REQUIRES A MINIMUM
SIDE -YARD SETBACK OF 12 FEET FROM PROPERTY LINE TO BE
REDUCED TO 8 FEET FROM PROPERTY LINE FOR THE PROPOSED FIRST
FLOOR ADDITION (APPROX. 430 SQ. FT.) TO THE EXISTING STRUCTURE.
Chair Stern called for a motion to open the public hearing.
MOTION: Member Axelrod moved to open the public hearing. Vice Chair Samuels
seconded the motion, which passed unanimously.
Chair Stern called for board members to disclose any ex parte communication, hearing
none, called on the Town Attorney to administer the oath to all those who would testify.
Town Attorney Rubin — There is a point that I want to make clear to the Board. The
property is a condominium association, so anything outside the actual units is the
Association's property. In order to actually construct the addition, the applicant will be
required to obtain approval from the association because he will be constructing those
improvements on association property. If the Board does grant the variance, it will be
subject to the association's approval prior to the issuance of any building permits.
Board of Adjustment & Appeals Regular Meeting
Wednesday, May 15, 2013 Page 4 of 7
Staff Presentation:
Building Official Michael Desorcy presented the variance petition. He indicated that he
was informed yesterday about the easement, which was mentioned at the site inspection.
The DOT has entered into an agreement with the association located at 4206 S. Ocean
Blvd., the Ocean Aire Condo Association. The Department of Transportation has a
permit from the South Florida Water Management District. All the work is going to be
located on the 4206 side of the property line and will not affect the property at 4210 S.
Ocean Blvd.
Deputy Town Clerk Oakes read into the record letters received from the following: Dr.
Karen Huffer, mother of Jordan Huffer (attached as Exhibit `A'); Anthony Chernalis,
4214 S. Ocean Blvd. (attached as Exhibit `B'); Steven Glanz, 4215 Tranquility Dr.
(attached as Exhibit `C') and Allen Teller, 4210 S. Ocean Blvd. Unit #1 (attached as
Exhibit 'D').
Petitioner's Presentation:
James Paine, Architect — The addition will be 12 feet away from the wall, which will give
us enough room to put a handicapped accessible tub with proper equipment and a
bedroom which is workable. If we were to build this addition within the allowable eight
feet, we could not create a maneuverable bathroom and bedroom. She cannot get upstairs
and we believe this is a legitimate hardship situation. The plans show elevations and we
tried to match the roof to keep the architectural style of the building. We are willing to
landscape as much as the Board would like, as well as our neighbors to the north. The
screen wall will also improve an existing condition where the air conditioners, electrical
equipment and garbage cans are visible, and we are willing to build it as high as six feet
which is allowable by code.
Jordan Huffer, Property Owner, 4210 S. Ocean Blvd. Unit #3 — I have been a resident of
Highland Beach since 2004. The purpose of the proposed addition is to accommodate
my mother who is 100% disabled. The four foot variance is the difference between a
bathroom and a bedroom that is functional versus not. We looked into other options, but
this is truly the only solution for us. My mother was to appear at this meeting but faced
some challenges yesterday and missed her flight. I spoke with several of my neighbors
regarding this variance explaining the situation. There are several letters from neighbors
recommending this variance be approved, including Allen Teller, the other neighbor in
my complex, who has already done an addition. This would suffice the majority in our
association in approving the application.
Public Statements:
Michael Thorson, 4206 S. Ocean Blvd., Unit 3 — My view would be directly over the
proposed addition and the most dramatically affected. I do feel for Jordan, but he does
have the option of moving. I would like to address the special circumstances that he
would have to fulfill to get a variance. The special circumstances that exist are peculiar
to the land or structure not applicable to other lands or structures in the district. The
peculiarity exists, not because of the way the residence is now which he has lived in for
several years, but because the applicant desires to modify the existing structure. So, the
Board of Adjustment & Appeals Regular Meeting
Wednesday, May 15, 2013 Page 5 of 7
peculiarity will only exist once his modifications are done. Second, the special
circumstances do not arise from the actions of the applicant. If he changes the way it is
now to suit his growing needs, then they will be too small in his own words. Third,
granting the variance requested will not confer on the applicant any special privilege that
is denied by this ordinance to other lands, buildings or structures in the same district. In
my opinion, granting a variance would convey special privileges because everyone else
has to comply with the setback requirements or meet justifiable criteria to receive the
variance. Since every piece of property is unique, it is hard to find a precedent; but I
would suggest the way that this property is unique is it is the only piece of property in
Florida, and I know you have seen it, that our building in a heavy flood is submerged for
weeks. I know they are putting in a drainage system but it doesn't always work. They
have tried to do it before. I am concerned that there will be more water displaced because
of the addition. I believe we have zoning to protect the privacy of the neighbors.
Mary Ann Ronco, 4206 S. Ocean Blvd — Unanimously, we are the four owners of the
building and are against the variance. There is not enough space between the buildings as
it stands now. We feel it will lower the property value of our building.
Norman Weinstein, 4207 Tranquility Dr . — We are directly across the canal from the
applicant. If the variance is denied, we would be willing to work with him to work
within the guidelines of the existing zoning regulations to come up with a viable solution
to accommodate him and his mother. Mr. Weinstein read sections from state law into the
record. I respectfully request that, given the fact that this request is not consistent with
Florida Law, it be rejected.
Joseph Frost, 4210 S. Ocean Blvd — I strongly oppose this variance. Read into the record
his concerns (attached as Exhibit `E'). This variance request is prohibited by our
Condominium Declarations. I understand that Mr. Teller, who is one of the owners at
4210 S. Ocean, sent in a letter of approval. Last night Mr. Teller sent me an email which
read he objects to the request for the variance (attached as Exhibit `F'). Based on Mr.
Teller's email, my objection and those of our neighbors directly to the north of us who
will be most affected, we strongly feel this variance should be denied.
Petitioner's Closing Statement:
Jordan Huffer, Petitioner — Mr. Teller has signed a letter of approval and I don't know
what goes back and forth in an email. I have a letter with a signature. Mr. Frost is not a
resident. He uses his properties as rentals. I am happy to work with all of the neighbors.
I am not trying to fight with my neighbors. I am trying to handle something for my
mother and make it usable. It is very difficult to make a bathroom for someone in a
wheelchair to use within the required setback. I know that the proposed dining room was
in question. The reason is that there is no way she can maneuver around the dining room
table that is in my house. I am not asking for special consideration or favors or
something of the nature that wouldn't be afforded to someone else. I am asking for four
feet.
Board Discussion:
Member Donaldson — My question is for Mr. Desorcy. The architect correctly pointed
out that if he does a structure at eight feet, by the time he finished with the insulation, dry
Board of Adjustment & Appeals Regular Meeting
Wednesday, May 15, 2013 Paze 6 of 7
wall etc., he will end up with about seven feet and two inches inside. Building Official
Desorcy — That is correct. The workable space would be a little over seven feet. The
Florida Building Code is 70 square feet for the dimensions of a bedroom.
Member Axelrod — If you took away the dining room, rotated the bed and bathroom, isn't
it conceivable to make a usable space and stay within the limits of the Town Ordinance?
James Paine — If you do away with the dining room, you are still limited by the eight feet
that you are allowed by right which would be just a little over seven feet. It still would
not be a comfortable handicapped accessible bathroom or bedroom. It would essentially
be a long hallway and not a good solution.
Vice Chair Samuels — Mr. Huffer, according to the paperwork given to us, it states that
this space would be provided for your mother when she visits. Mr. Huffer — It is not for
when she visits. She lives in Colorado and the winters are bad for her, so she will be here
during the winter and perhaps full -time eventually.
Member Donaldson — I have a question for the Architect. Is there anything in the
ADA/Fair Housing Act that compels this particular arrangement? James Paine — I have
not studied it to that extent.
Chair Stern called for a motion to approve /deny the variance request at 4210 S. Ocean
Blvd., Unit 3, Highland Beach.
MOTION: Member Axelrod moved to deny the request for variance at 4210 South
Ocean Blvd., Unit 3, Highland Beach. Member Weiss seconded the motion.
Town Attorney Rubin — Member Axelrod, can you please state your bases on the motion?
Member Axelrod — I think that our job here is basically to protect the Town and the
residents of the Town. I wouldn't have a problem with this if so many residents weren't
arguing against it. If they feel that their property is being deteriorated because of this,
then I feel it is our job to protect them.
_Town Attorney Rubin — In terms of the criteria, the Board's job is to determine whether
the criteria set forth in the Code is met. Is your motion based on the fact that the petition
does not meet the criteria in the code? Board Member Axelrod — It does not meet the
criteria and to grant an exception of that broad a range would not be proper at this point.
Member Weiss accepted the comments made by Board Member Axelrod.
Roll Call:
Member Axelrod - Yes
Member Weiss - Yes
Member Perilman - Yes
Member Donaldson - Yes
Vice Chair Samuels - Yes
Chair Stern - Yes
Motion carried 6/0.
Board of Adjustment & Appeals Regular Meeting
Wednesday, May 15, 2013 Page 7 of 7
Chair Stern called for a motion to close the public hearing at 3:17 PM.
MOTION: Vice Chair Samuels moved to close the public hearing 3:17 PM. Member
Weiss seconded the motion, which passed unanimously.
ADJOURNMENT:
Being no further business, Chair Stern called for a motion to adjourn the meeting at 3:17
PM.
MOTION: Member Weiss moved to adjourn the meeting at 3:17 PM. Vice Chair
Samuels seconded the motion, which passed unanimously.
APPROVED:
David Stan, Chair
Ruth Samuels, Vice
TOWN SEAL C
Barry Axelro , oard mber
Tonalason, Board Member
ATTESTED: Evelyn W s, Boar e e
Bryan Pe an
ti_ Valerie Oakes, CMC
Deputy Town Clerk
Appointed Board Secretary Y
Date:
BOARD of ADJUSTMENT & APPEALS
MAY 15, 2013 — REGULAR MEETING
EXHIBITS TO THE MINUTES:
Variance Request:
Application No. 29605 — 4210 S. Ocean Blvd., Unit 3 — Jordan Huffer, Petitioner
Exhibit A — Letter from Dr. Karen Huffer (Petitioner's Mother) (pgs. 1 -24)
Exhibit B — Letter from Anthony Chernalis of 4214 S. Ocean Blvd. (pg. 25)
Exhibit C — Letter from Steven Glanz of 4215 Tranquility Drive (pg. 26)
Exhibit D — Letter from Allen Teller of 4210 S. Ocean Blvd., Unit #1 (pg. 27)
Exhibit E — Letter of Concerns from Joseph Frost of 4210 S. Ocean Blvd., Unit #2 (pgs. 28 -30)
Exhibit F — Email from Allen Teller provided by Joseph Frost (pg. 31)
Letter attesting to seed for relief wader Federal and Florida Fair Housing Laws
TO: TOWN OF HIGHLAND BEACH (Attention Valerie - FAX 561- 265 -3582)
BOARD OF ADJUSTMENT 8t APPEALS
RE: SPECIAL, MEETING
Wednesday, May 15, 2013
2:00 PM
Variance Request: 4210 South Ocean Blvd. — Public H
caring Application No. 29605 — Relief from Highland Beach Code of
Ordinances Section 30-64, Table 30-2, that requires a minimum side -yard
setback of 12 feet from property line to be reduece to 8 feet from property
line for the proposed first floor addition (approx. 430 sq. R.) to the existing
structure.
Dear Board:
Unfortunately. my planned plane trip (see ticket attached) to Florida on May 14, 2013, was
unsuccessful because the car transporting me to the Denver Airport broke down. I arrived too
late and was not able to rebook by the time of today's meeting. Please accept this letter to
support my son, Jordan Huffer's testimony. It is my intention to cooperate fully with the board
providing information as needed. Due to the confidentiality requirements of the Americans with
Disabilities Act Amendments act and the Federal and Florida Fair Housing Laws (summarized
DOYHUD attached) for persons with disabilities, I had intended to be at this meeting to
personally verify and testify to facts about my severe physical disability to assist the Board
waiving certain areas of privilege if needed. The facts are simple:
I. I am nearly 72 years of age. I was pushed down in a grocery store breaking bones in my left
leg and hip. I have hardware in my left leg. I also.sustained an upper motor neuron lesion
causing me imbalance and weakness complicating my ability to recover.
2. can walk very short distances with a walker but must use a wheelchair for most purposes. I
axe considered 10094 disabled.
3. I must stay with my son, Jordan Huffer, at least for winters and soon year around.
4. I cannot manage to get upstairs at his home at 4210 South Ocean Drive and must have special
modifications as provided for under the Federal Law.
5. The modification would be a small room with assistive devices, walk in bathtub, hand rails
etc. so I have equal access and quality of living as much as possible.
Please accept this as my declaration and under penalty of perjury I sign this document.
Respectfullyy,,
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Reservation Confirmation
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To: JORDAN HUFFER <IegslabuseAgnlal.00uhv
F yMM 7001 T r Allure Inc.
f Ll 7001 Tower Road
Denver, CO 80249
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tilrherery:
Booking Confirmation
Reserml n Cc": KO=C Win corded Dr Karin Huffer
Issue Dale: Thu, 02 May 2013 E -mail: jordanQmotorgroup.com
Home phone: 954- 6467447
Passengers
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of 7
5/15/13 7:46 AM
U.S. DEPARTMENT OF JUSTICE
CIVIL RIGHTS DIVISION
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
OFFICE OF FAIR HOUSING AND EQUAL OPPORTUNITY
IParkfagaa, D.C.
May 17, 2004
JOINT STATEMENT OF
THE DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
AND T13E DEPARTMENT OF JUSTICE
REASONABLEACCOMMODATIONS UNDER THE
FAIR MOUSING ACT
IIItr'odlrctlOn
The Department of Justice ("DOJ ") and the Department of Housing and Urban
Development ( "HUD ") are jointly responsible for enforcing the federal Fair Housing Act' (the
"Act"), which prohibits discrimination in housing on the basis of race, color, religion, sex,
national origin, familial status, and disability.' One type of disability discrimination prohibited
by the Act is the refusal to make reasonable accommodations in rules, policies, practices, or
services when such accommodations may be necessary to afford a person with a disability the
equal opporhmity to use and enjoy a dwelhng. HUD and DOJ fiequently respond to complaints
alleging that housing providers have violated the Act by refusing reasonable accommodations to
persons with disabilities. Ttiis Statement provides technical assistance regarding the rights and
Obligations of persons with disaabilities and housing providers under the Act relating to
' The pair Housing Act is codified at 42 U.S.C. §§ 3601 - 3619.
2 The Act uses the term "handicap" instead of the term "disability." Both terms have the
same legal meaning. See Bmn v. Abb ott 524 U.S. 624, 631 (1998) (noting that definition of
" disability" in the Americans with Disabilities Act is drawn almost verbatim `Prom the definition
of'haodicap' contained in the Fair Housing Amendments Act of 1988"). This document uses the
term "disability;' which is more generally accepted.
' 42 U.S.C. § 3604(f )(3)(B).
reasonable accommodations.°
Questions and Answers
1. What types oPdiaerimination against persons with disabilities does the Act
prohibit?
The Act prohibits lousing providers from discriminating against applicants or residents
because of their disability or the disability of anyone associated with thems and from treating
persons with disabilities less favorably than others because of their disability. The Act also
makes it unlawful for any person to refuse "to make reasonable accommodations in rules,
Policies, practices, or services, when such accommodations may be necessary to afford ...
P erson(
'4 (with disabilities) equal opportunity to use and enjoy a dwelling.'' The Act also
prohibits housing providers from refusing residency to persons with disabilities, or placing
conditions on their residency, because those persons may require reasonable accommodations.
In addition, in certain circumstances, the Act requires that housing providers allow residents to
Housing providers that receive federal financial assistance are also subject to the
requirements of Section 504 of the Rehabilitation Act of 1973. 29 U.S.C. § 794. Section 504,
and its implementing regulations at 24 C.F.R. Part 8, Prohibit discrimination based on disability
and require recipients of federal financial assistance to provide reasonable a 'ommodations to
applicants and residents with disabilities. Although Section 504 imposes greater obligations than
the Fair Housing Act, (e.g., providing and paying for reasonable accommodations that involve
structural modifications to units or public and common areas), the principles discussed in this
Statement regarding reasonable accommodation under the Fair Housing Act generally apply to
requests for reasonable accommodations to rules, policies, practices, and services under Section
504. See U.S. Department of Housing and Urban Development, Office of Public and Indian
Housing, Notice PIH 2002 -01(HA) (www.hud.9 offices /fheo/ftabilities/MO2- 0i.pdf) and
"Section 504: Frequently Asked Questions; (www.hud.gov /Of BcWfheo /disabilities/
sect504faq.cfin#anchor272118)_
s The Fair Housing Act's protection against disability discrimination covers not only
home seekers with disabilities but also buyers and renters without disabilities who live or
are associated with individuals with disabilities 42 U.S.C. § 3604(f)(1)(B), 42 U.S.C.
§ 3604(f)(1)(C), 42 U.S.C. § 3604(f)(2XB), 42 U.S.C. § (t)(2)(4 See also H.R. Rep. 100 -711 —
24 (reprinted in 1988 U.S.C.A.N. 2173, 2184 -85) ( "The Committee intends thew provisions to
prohibit not only.discrimination against the primarypurchaser or named lessee, but also to
prohibit denials ofhousing opportunities to applicants because they have children, parents,
friends, spouses, roommates, patients, subtenants or other associates who have disabilities.
Accord: Preamble to Proposed HUD Rules Lnplementing the Fair Act, 53 Fed. Reg
45001 (Nov. 7, 1986) (citing'House Report).
6 42 U.S.C. § 3604(0(3)(B). HUD reg gul pertaining to reasonable accommodati
may be found at 24 C.F.R. § 100.204.
-2-
make reasonable structural modifications to units and public/common areas in a dwelling when
those modifications may be necessary for a person with a disability to have full enjoyment of a
dwelling! With certain limited exceptions (see response to question 2 below), the Act applies to
privately and publicly owned housing, including housing subsidized by the federal government or
rented through the use of Section 8 voucher assistance.
2. Who must comply with the Fair Housing Act's reasonable accommodation
requirements?
Any person or entity engaging in prohibited conduct — i.e., refusing to male reasonable
accommodations in rules, policies, practices, or services, when such accommodations may be
necessary to afford a person with a disability an equal opportunity to use and enjoy a dwelling —
may be held liable unless they fall within an exception to the Act's coverage. Courts have
applied the Act to individuals, corporations, associations and others involved in the provision of
housing and residential lending, including property owners, housing managers, homeowners and
condominium associations, lenders, anal estate agents, and brokerage services. Courts have also
applied the Act to state and local governments, most often in the context of exclusionary zoning
of other land -use decisions. See e.g., City of Edmonds v. Oxford House, Inc ., 514 U.S. 725, 729
(1995); P[giiect Life v. GlendenW 139 F. Supp. ?03, ?10 (D. Md. 2001), A= 2002 WL
2012545 (4* Cir. 2002). Under specific exceptions to the Fair Housing Act, the reasonable
accommodation requirements of the Act do not apply to a private individual owner who sells his
own home so long as he (1) does not own more than three single - family homes; (2) does not use
a real estate agent and does not employ any discriminatory advertising or notices; (3) has not
engaged in a similar sale of a home within a 24 -month period; and (4) is not in tlx: business of
selling or renting dwellings. The reasonable accommodation requirements of the Fair Housing
Act also do not apply to owner - occupied buildings that have four or fewer dwelling units.
3. Who qualifles as a person with a disability under. the Act?
The Act dofnes a person with a disability to include (1) individuals with a physical or
mental impairment that substantially limits one or more major life activities; (2) individuals who
are regarded as having such an impairment; and (3) individuals with a record ofsuch an
impairment.
The term "physical or mental impairment" includes, but is not limited to, such diseases
and conditions as orthopedic, visual, speech and hearing impairments, cerebral palsy, autism,
epilepsy, muscular dystrophy, multiple sclerosis, cancer, heart disease, diabetes, Human
Ymmunodeficiency Virus infection, mental retardation, emotional illness, drug addiction (other
than addiction caused by cun-ent, illegal use of a controlled substance) and alcoholism.
This Statement does not address the principles relating to reasonable modifications.. For
finther information see the HUD regulations at 24 C.FR § 100.203. This statement also does
not address the additional requirements imposed on recipients of Federal financial assistance
pursuant to Section 504, as explained in the Introduction.
-3-
The term "substantially limits" suggests that the limitation is "significant" or "to a large
d eg r ee. "
The term "major life activity means those activities that are of central importance to
daily life, such as seeing, hearing, walking breathing, performing manual tasks, caring for one's
self, learning, and speaking.' This list of major life activities is not exhaustive. See e.g., Bm¢ ad
I AI:2611. 524 U.S. 624, 691 -92 (1998)(holding that for certain individuals reproduction is a
major life activity).
4. Does the Act protect juvenile offenders, sex offenders, persons who illegally use
controlled substances, and persons with disabilities who pose a significant danger to
others?
No, juvenile offenders and sex offenders, by virtue of that status, are not persons with
disabilities protected by the Act. Similarly, while the Act does protect persons who are
recovering from substance abuse, it does W protect persons who are currently engaging in the
current illegal use of controlled substances? Additionally, the Act does not protect an individual
with a disability whose tenancy would constitute a "direct threat" to the health or safety of other
individuals or result in substantial physical damage to the property of others unless the threat can
be eliminated or significantly reduced by reasonable accommodation.
5. How can a housing provider determine ff an individual poses a direct threat?
The Act does not allow for exclusion of individuals based upon fear, speculation, or
stereotype about a particular disability orpersons with disabilities in general. A determination
that an individual poses a direct threat must rely on an individualized assessment that is based on
reliable objective evidence (e.g., current conduct, or a recent history of overt acts). The
assessment must consider; (1) the nature, duration, and severity of the risk of injury, (2) the
probability that injury will actually occur; and (3) Vðer there am any reasonable
accommodations that will eliminate the direct threat. Consequently, in evaluating a recent
history of overt acts, a provider must take into account whether the individual has received
intervening treatment or medication that has eliminated the direct threat (i.e., a significant risk of
substantial harm). In such a situation, the provider may request that the individual document
° The Supreme Court has questioned but has not yet ruled on whether "working" is to be
considered a major life activity. $$m Toyota Motor Mfg, Kentucky Inc v wil es, 122 S. Ct.
681, 692, 693 (2002). if it is a major activity, the Court has noted that a claimant would be
required to show an inability to work in a "broad range of jobs" rather than a specific job. See
$y Qq v. United Ai_rlWa rnc;_ 527 U.S. 470,492 (1999).
See, e.g., United States v. Southern Mmilgg= G 955 F.2d 914, 919 (4 11 Cir. 1992)
(discussing exclusion in 42 U.S.C. § 3602(h) for `current, illegal use of or addiction to a
controlled substance
-4-
how the circumstances have changed so that he no longer poses a direct threat. A provider may
also obtain satisfactory assurances that the individual will not pose a direct threat during the
tenancy. The housing provider must have reliable, objective evidence that a person with a
disability poses a direct threat before excluding him from housing on that basis.
Example l: A housing provider requires all persons applying to rent an
apartment to complete an application that includes information on the applicant's
current place of residence. On her application to rent an apartment, a woman
notes that she currently resides in Cambridge House. The manager of the
apartment complex knows that Cambridge House is a group home for women
receiving treatment for alcoholism. Based solely on that information and his
personal . belief that alcoholics are likely to cause disturbances and damage
property, The manager rejects the applicant. The rejection is unlawful because it is
based on a generalized stereotype related to a disability rather than an
individualized assessment of any threat to other persons or the property of others
based on reliable, objective evidence about the applicant's recent past conduct.
The housing provider may not treat this applicant differently than other applicants
based on his subjective perceptions of the potential problems posed by her
alcoholism by requiring additional documents, imposing different lease terms, or
requiring a higher security deposit. However; the manager could have checked
this applicant's references to the same extent and in the same manner as he would
have checked any other applicant's references- If such a reference check revealed
objective evidence showing that this applicant had posed a direct threat to persons
or property in the recent past and the direct threat had not been eliminated, the
manager could then have rejected the applicant based on direct threat.
Example 2: James X, a tenant at the Shady Oaks apartment complex, is
arrested for threatening his neighbor while brandishing a baseball bat. The Shady
Oaks' lease agreement contains a term prohibiting tenants from threatening
violence against other residCats. Shady Oaks' rental manager investigates the
incident and Icarus that James X threatened the other resident with physical
violence and had to be physically restrained by other neighbors to keep him from
acting on his threat. Following Shady Oaks' standard practice of strictly enforcing
its "no threats" policy, the Shady Oaks rental manager issues James X a 30-day
notice to quit, which is the first step in the eviction process. James X's attorney
contacts Shady Oaks' rental manager and explains that James X has a psychiatric
disability that causes him to be physically violent when he "s taking his
prescribed medication. Suggesting that his client will not pose a direct threat to
Wien if proper safeguards are taken, the attorney requests that the rental manager
grant James X an ocception to the "no threats" policy as a reasonable
accommodation based on James X's disability. The Shady Oaks rental manager
need only grant the reasonable accommodation if James X's attomaycan provide
satisfactory assurance that James X will receive appropriate counseling and
-5-
periodic medication monitoring so that he will no longer pose a direct threat
during his tenancy. After consulting with James X, the attorney responds that
James X is unwilling lo receive counseling or submit to any type of periodic
monitoring to ensure that he takes his prescribed medication. The rental manager
may go forward with the eviction proceeding, since James X continues m pose a
direct threat to the health or safety of other residents.
6. What is a "reasonable accommodation" for purposes of the Act?
A "reasonable accommodation" is a change, exception. or adjustment to arule, policy,
practice, or service that may be necessary for a person with a disability to have an equal
opportunity In use and enjoy a dwelling, including public and common use spaces. Since rules,
policies, practices, and services may have a different effect on persons with disabilities than on
other persons, treating persons with disabilities exactly the same as others will sometimes deny
them an equal opportunity to use and enjoy a dwelling. The Act makes it unlawful to refuse to
make reasonable accommodations to rules, policies, practices, or services when such
accommodations may be necessary to afford persons with disabilities an equal opportunity to use
and enjoy a dwelling.
To show that a requested accommodation may be necessary, there must be an identifiable
relationship, or nexus, between the requested accommodation and the individual's disability.
Example 1: A housing provider has a policy of providing unassigned pa&ing
spaces to residents. A resident with a mobility impairment, who is substantially
limited in her ability to walk, requests an assigned accessible parking space close
to the entrance to her unit as a reasonable accommodation. There are available
parking spaces near the entrance to her unit that are accessible, but those spaces
are available b all residents on a first come, first served basis. The provider must
make an exception b its policy ofnot providing assigned parking spaces to
accommodate this resident.
Example 2: A housing provider has a policy of requiring tenants to. crane to the
rental office in person to pay their rent. A tenant has a mental disability that
makes her afraid to leave her unit. Because of her disability, she requests that she
be permitted to have a. friend. mail her rent payment to the rental office as a
reasonable accommodation. The provider must make an exception to its payment
Policy to accommodate this tenant.
Example 3: A housing provider has a "no pets" policy. A tenant who is deaf
requests that the provider allow him to keep a dog in his unit as a reasonable
accommodation. the tenant explains drat the dog is an assistance animal that will
alert him to several sounds, including knocks at the door, sounding of the smoke
detector, the telephone ringing, and cars coming into the driveway. The housing
-6-
provider must make an exception to its `ho pets" polic to accommodate this
tenant.
7. Are there any Instances when a provider can deny a request for a reasonable
accoamodation without violating the Act?
Yes. A housing provider can deny a request for a reasonable accommodation if the
request was not made by or on behalf of a person with a disability or if there is no disability -
related need for the accommodation. In addition, a request for a reasonable accommodation may
be denied if providing the accommodation is not reasonable — i.e., if it would impose an undue
financial and administrative burden on the housing provider or it would fundamentally alter the
nature of the provider's Operations. The determination of undue financial and administrative
burden must be made on a case -by -case basis involving various factors, such as the cost of the
requested accommodation, the financial resources of the provider, the benefits that the
accommodation would provide to the requester, and the availability of alternative
accommodations that would effectively meet the requester's disability - related needs.
When a housing provider refuses a requested accommodation because it is not reasonable,
the provider should discuss with the requester whether there is an alternative accommodation that
would effectively address the requester's disability - related needs without a fundamental alteration
to the provider's operations and without imposing an undue financial and administrative burden.
If an alternative accommodation would effectively meet the requester's disability- related needs
and is reasonable, the provider must grant it. An interactive process in which the housing
provider and the requester discuss the requester's disability - related need for the requested
accommodation and possible alternative accommodations is helpful to all concerned because it
often results in an effective accommodation for the requester that does not pose an undue
financial and administrative burden for the provider.
Example: As a result of a disability, a tenant is physically unable to open the
dumpster placed in the parking [at by his housing provider for trash collection.
The tenant requests that the housing provider send a maintenance staffpeison to
his _apartment on a daily basis to collect his trash and take it to the dumpster.
Because the housing development is a small operation with limited financial
resources and the. maintenance staff are on site only twice per week, it may be an
undue financial and administrative burden for the housing provider to grant the
requested daily trash pick -up service. Accordingly, the requested accommodation
may not be reasonable. If the housing provider denies the requested
accommodation as unreasonable, the housing provider should discuss with the
tenant whether reasonable accommodations could be provided to meet the tenant's
disability- related needs — for instance, placing an open trash collection can in a
location that is readily accessible to the tenant so the tenant can dispose of his
own trash and the provider's maintenance staff can then transfer the trash to the
dumpster when they are on site. Such an accommodation would not involve a
-7-
fundamental alteration of the provider's operations and would involve little
financial and administrative burden for the provider while accommodating the
tenant's disability- related needs.
There may be instances where a provider believes that, while the accommodation
requested by an individual is reasonable, there is an alternative accommodation that would be
equally effective in meeting the individual's disability - related needs. In such a circumstance, the
provider should discuss with the individual if she is willing to accept the alternative
accommodation. However, providers should be aware that persons with disabilities typically
have the most accurate knowledge about the functional limitations posed by their disability, and
an individual is not obligated to accept an alternative accommodation suggested by the provider
if she believes it will not meet her needs and her preferred accommodation is reasonable.
8. What is a "fundamental alteration "?
A °fundamental alteration" is a modification that alters the essential nature of a provider's
operations.
Example: A tenant has a severe mobility impairment that substantially limits his
ability to walk. He asks his housing provider to transport him to the grocery store
and assist him with his grocery shopping as a reasonable accommodation to his
disability. The provider does not provide any transportation or slopping services
for its tenants, so granting this request would require a fundamental alteration in
the nature of the provider's operations. The request can be denied, but the
provider should discuss with the requester whether there is any alternative
accommodation that would effectively meet the requester's disability-related needs
without f indgmentally altering the nature of its operations, such as reducing the
tenant's need to walk long distances by altering its paddag policy to allow a
volunteer from a local community service organization to park her car close to the
tenant's unit so slre can transport *a taunt to the groccry start and assist him
with his shopping.
9. What happens if providing a requested accosnmodadoa involves some costs on
the part of the housing provider?
Courts have ruled that the Act may require a housingprovider to grant a reasonable
accommodation that involves costs, so long as the reasonable accommodation does not pose an
undue financial and administrative burden and the requested accommodation does not constitute
a fundamental alteration of the provider's operations. The financial resources of the provider, the
cost of the reasonable accommodation, the benefits to the requester of the requested
accommodation, and the availability of other, less expensive alternative accommodations that
would effectively meet the applicant or resident's disability- related needs must be considered in
determining whether a requested accommodation poses an undue financial and administrative
_8_
burden.
10. What happens if no agreement can be reached through the interactive process?
A failure to reach an agreement on an accommodation request is in effect a decision by.
the provider not to giant the requested accommodation. If the individual who was denied an
accommodation files a Fair Housing Act complaint to challenge that decision, then the agency or
court receiving the complaint will review the evidence in light of applicable law- and decide if
the housing provider violated that law. For more infomnation about the complaint process, see
question 19 below.
I1. May a housing provider charge an extra fee or require an additional deposit
from applicants' or residents with disabilities as a condition of grouting a reasonable
accommodation?
No. Housing providers may not require persons with disabilities to pay extra fees or
deposits as a condition of receiving a reasonable accommodation.
Example 1: A man who is substantially limited in his ability ia walk uses a
motorized scooter for mobility purposes. He applies to live in an assisted living
facility that has a policy prohibiting the use of motorized vehicles in buildings and
elsewhere on the premises. It would be a reasonable accommodation for the
facility to make an exception to this policy to permit the man to use his motorized
scooter on the premises for mobility purposes. Since allowing the man to use his
scooter in the buildings and elsewhere on the premises is a reasonable
accommodation, the facility may not condition his use of the scooter on payment
of a fee or deposit or on a requirement that he obtain liability insurance relating to
the use of the scooter. However, since the Fair Housing Act does not protect any
person with a disability who poses a direct threat to the person or property of
others, the man must operate his motorized acootcr in a responsible manner that
does not pose a significant risk to the safety of other persons and does not cause
damage to other persons' Property. If the individual's use of the scooter causes
damage to his unit or the common areas, the housing provider may charge him for
the cost of repairing the damage (or deduct it Timm the standard security deposit
imposed on all tenants), if it is the provider's practice to assess tenants for any
damage they cause to the premises.
Example 2: Because of his disability, an applicant with a hearing impairment
needs to keep an assistance animal in his unit as a reasonable wm mrnodation.
The housing provider may not require the applicant to pay a fee or a security
deposit as a condition of allowing the applicant to keep the assistance animal.
However, if a tenant's assistance animal causes damage to the applicantlk unit or
the common areas of the dwelling, the housing provider may diarge the tenant for
_9_
the cost of repairing the damage (or deduct it from the standard security deposit
imposed on all tenants), if it is the providers practice to assess tenants for any
damage they cause to the premises.
12. When and how should an individual request an accommodation?
Under the Act, a resident or an applicant for housing makes a reasonable accommodation
request whenever she makes clear to the housing provider that she is requesting an exception,
change, or adjustment to a rule, policy, practice, or service because of her disability. She should
explain what type of accommodation she is requesting and, if the need for the accommodation is
not readily apparent or not known to the provider, explain the relationship between the requested
accommodation and her disability.
An applicant or resident is not entitled to receive a reasonable accommodation unless she
requests one. However, the Fair Housing Act does not require that a request be made in a
Particular manner or at a particular time. A person with a disability need not pezonally make the
reasonable accommodation. request; the request can be made by a family member or someone
else who is acting on her behalf. An individual making a reasonable accommodation request
does not need to mention the Act or use the words "reasonable accommodation." However, the
requester must make the request in a manner that a reasonable person would understand to be a
request for an exception, change, or adjusnnem to a rule, policy, practice, or service because of a
disability.
Although a reasonable accommodation request can be made orally or in writing, it is
usually helpful for both the resident and the housing provider if the request is made in writing
This will help prevent misunderstandings regarding what is being requested, or whether the
request was made. To facilitate the processing and consideration of the request, residents or
prospective residents may wish to check with a housing provider in advance to determine if the
provider has a preference regarding the manner in which the request is made. However, housing
providers must give appropriate consideration to reasonable accommodation requests even if the
requester makes the request orally or does not use the provider's preferred Eorms or procedures
for making such requests.
Example: A tenant in a large apartment building makes an oral request that she
be assigned a mailbox in a location that she can easily access because of a
Physical disability that limits her ability to reach and bend. The provider vwuld
prefer that the tenant make the accommodation request on a pre - printed form, but
the tenant fails to complete the fom4. The provider must consider the reasonable
accommodation request even though the tenant would not use the provider's
designated fonn.
13. Must a housing provider adopt formal procedures for processing requests for a
reasonable accommodation?
-10-
No. The Act does not require that a housing provider adopt any formal procedures for
reasonable accommodation requests. However, having formal procedures may aid individuals
with disabilities in making requests for reasonable accommodations and may aid housing
providers in assessing those requests so that there are no misunderstandings as to the nature of
the request, and, in the event of later disputes, provide records to show that the requests received
proper consideration.
A provider may not refuse a request, however, because the individual making the request
did not follow any formal procedures that the provider has adopted. If a provider adopts formal
procedures for processing reasonable accommodation requests, the provider should ensure that
the procedures, including any forms used, do not seek information that, is not necessaryto
evaluate if a reasonable accommodation may be needed to afford a person with a disability equal
opportunity to use and enjoy a dwelling. See Questions 16 -18, which discuss the disability-
related-information that a provider may and may not request for the purposes of evaluating a
reasonable accommodation request..
14. L a bowing provider obligated to provide a reasonable accommodation to a
resident or applicant if an accommodation has not been requested?
No. A housing provider is only obligated to provide a reasonable accommodation to a
resident or applicant if a request for the accommodation has been made. A provider has notice
that a reasonable accommodation request has been made if a person, her family member, or
someone acting on her behalf requests a change, exception, or adjustment to a rule, policy,
practice, or service because of a disability, even ifthe words "reasonable accommodation" are
not used as part of the request.
15. What if a housing provider fails to act promptly on a reasonable
accommodation request?
A provider has an obligation to provide prompt responses to reasonable accommodation
requests. An undue delay in responding to a reasonable accommodation request may be deemed
to be a failure to provide a reasonable accommodation.
16. What inquiries, if any, may a housing provider make of current or potential
residents regarding the existence of a disability when they have not asked for an
accommodation?
Under the Fair Housing Act, it is usually unlawful for a housing provider to (1) ask if an
applicant for a dwelling has a disability or if a person intending to reside in a dwelling or anyone
associated with an applicant or resident has a disability, or (2) ask about the nature or severity of
such persons' disabilities. Housing providers may. however, make the following inquiries,
Provided these inquiries are made of all applicants, including those with and without disabilities:
-11-
An inquiry into as applicant's ability to meet the requirements of tenancy;
• An inquiry to determine if an applicant is a current illegal abuser or addict
of a controlled substance;
• An inquiry to determine if an applicant qualifies for a dwelling legally
available only to persons with a disability or to persons with a particular
type of disability; and
• An inquiry to determine if an applicant qualifies for housing that is legally
available on a priority basis b persons with disabilities or to persons with
a particular disability.
Example 1: A. housing provider offers accessible units to persons with
disabilities needing the features of these units on a priority basis. The provider
may ask applicants if they have a disability and if, in light of their disability, they
will benefit from the features of the units. However, the provider may not ask
applicants if they have other types ofphysical or mental impairments. If the
applicant's disability and the need for the accessible features are not readily
apparent, the provider may request reliable information/documentation of the
disability- related need for an accessible unit
Example 2: A housing provider operates housing that is legally limited to
persons with chronic mental illness. The provider may ask applicants for
information needed to determine ifthey have amental disability that would
qualify theta for the housing. However, in this circumstance, the provider may
not ask applicants if they have other types of physical or mental impairments. if it
is not readily apparent that an applicant has a chronic mental disability, the
provider may request reliable information/documentation of the mental disability
needed to qualify for the housing.
In some instances, a provider may also request certain information about an applicant's or
a resident's disability if the applicant or resident requests a reasonable accommodation. See
Questions 17 and l8 below.
17. What kinds of information, if any, may a housing provider request from a
person with ad obvious or known disability who is requesting a reasonable
aecommodaden?
A provider is entitled to obtain information that is necessary to evaluate if a requested
reasonable accommodation maybe necessary because of a disability. If a person's disability is
obvious, or otherwise .known to the provider, and if the need for the requested accommodation is
also readily apparent or known, then the provider maynot request any additional information
-12-
about the requester's disability or the disability - related need for the accommodation.
If the requester's disability is known or readily apparent to the provider, but the need for
the accommodation is not readily apparent or known, the provider may request only information
that is necessary to evaluate the disability - related need for the accommodation.
Example 1: An applicant with an obvious mobility impairment who regularly
uses a walker to move around asks her housing provider to assign her a parking
space near the entrance to the building instead of a space located in another part of
the parking lot Since the physical disability (i.e., difficulty walking) and the
disability - related need for the requested accommodation are both readily apparent,
the provider may not require the applicant to provide any additional information
about her disability or the need for the requested accommodation.
Example 2: A rental applicant who uses a wheelchair advises a housing provider
that he wishes to keep an assistance dog in his unit even though the provider has a
"no pets" policy. The applicant's disability is readily apparent but the need for an
assistance animal is not obvious to the provider. The housing provider mayask
the applicant to provide information about the. disability - related need for the dog.
Example 3: An applicant with an obvious vision impairment requests that the
leasing agent provide assistance to her in filling out the rental application form as
a reasonable accommodation because of her disability. The housing provider may
not require the applicant to document the existence of her vision impairment.
18. U a disability is not obvious, what kinds of information nay a housing provider
request from the person with a disability in support of a requested aecommodation?
A housing provider may not ordinarily inquire as to the nature and severity of an
individual's disability (see Answer 16, above). However, in response to a request for a
reasonable accommodation, a housing provider may request reliable disability - related
information that (1) is necessary to verify that the person meets the Act's definition of disability
(Le., has a physical or mental impairment that substantially limits one or more majar life
activities), (2) describes the needed accommodation, and (3) shows the relationship between the
person's, disability and the need for the requested accommodation. Depending on the
individual's circumstances, information verifying that the person meets the Act's definition of
disability can usually be provided by the individual himself or herself (e.g., proof that an
individual under 65 years of age receives Supplemental Security Income or Social Security
Disability Insurance benefits or a credible statement by the individual). A doctor or other
10 Persons who meet the definition of disability for purposes of receiving Supplemental
Security Income ( "SSr') or Social Security Disability Insurance ( "SSDI ") benefits in most cases
meet the definition of disability under the Fair Housing Act, although the converse may not be
Me., Sae e.g., �gl ,y (gam v. Policy Manaaen a t Systems Coro 526 U.S. 795, 797 (1999)
-13-
medical professional, a peer support group, a non - medical service agency, or a reliable third party
who is in a position to know about the individual's disability may also provide verification of a
disability. In most cases, an individual's medical records or detailed information about the nature
of a person's disability is not necessary for this inquiry.
Once a housing provider has established that a person meets the Act's definition of
disability, the provider's request for documentation should seek only the information that is
necessary to evaluate if the reasonable accommodation is needed because of a disability. Such
information must be kept confidential and must not be shared with other persons unless they
need the information to make or assess a decision to grant or deny a reasonable accommodation
request or unless disclosure is required by law (e.g., a court- issued subpoena requiring
disclosure).
19. U a person believes she has been unlawfully denied a reasonable
accommodation, what should that person do if she wishes to challenge that denial under the
Act?
When a person with.a disability believes that she has been subjected to a discriminatory
housing practice, including a provider's wrongful denial of a request for reasonable
accommodation, she may file a complaint with HUD within one year after the alleged denial or
may file a lovsuit.in federal district court within two years of the alleged denial. If a complaint is
filed with HUD, HUD will investigate the complaint at no cost to the person with a disability.
11ere are several ways that a person may file a complaint with HUD:
• By placing a toll -free call to 1- 800 -669 -9777 or TTY 1 -800- 927 -9275;
• By completing the ` on -lind' complaint form a railable on the HUD internet site:
httdJ /www.bud.eov, or
• By wing a completed complaint form or letter to:
Office of FairHousing and Equal Opportunity
Department of Housing & Urban Development
451 Seventh Street, S.W., Room 5204
Washington, DC 20410 -2000
(noting that SSDI provides benefits to a person with a disability so severe that she is unable to do
her previous wodc and cannot engage in any other kind of substantial gainful wodc whereas a
person pursuing an action fvr disability discrimination under the Americans with Disabilities Act
may state a claim that "with a reasonable accommodation' she could perform the essential
functions of the job).
-14-
Upon request, HUD will provide printed materials in alternate formati (large prim audio
tapes, or Braille) and provide complainants with assistance in reading and completing forms.
The Civil Rights Division of the Justice Department brings lawsuits in federal courts
across the country to and discriminatory practices and to seek monetary and other relief for
individuals whose rights under the Fair Housing Act lave been violated. The Civil Rights
Division initiates lawsuits when it has reason to believe that a person or .entity is involved in a
"pattern or practice of discrimination or when there has been a denial of rights to a group of
persons that raises an issue of general public importance. The Division also participates as
aattcws curiae in federal court cases that raise important legal questions involving the application
and/or interpretation of the Act. To alert the Justice Department to matters involving a pattern or
practice of discrimination, matters involving the denial of rights to groups of persons, or lawsuits
raising issues that may be appropriate foramicus participation, contact:
U.S. Department of Justice
Civil Rights Division
Housing and Civil Enforcement Section — G St.
950 Pennsylvania Avenue, N.W.
Washington, DC 20530
For more information on the types of housing discrimination cases bandled by the Civil
Rights Division, please refer to the Housing and Civil Enforcement Section's website at
httv://www.usdoi. eov /crt/housinzArehc me htrnl
A HM or Department of Justice decision not to proceed with a Fair Housing Act matter
does not foreclose private plaintiffs fiom pursuing a private lawsuit. However, litigation can be
an expensive, tithe- consuming, and uncertain process for all parties. HUD and the Department of
Justice courage parties to Fair Housing Act disputes to explore all reasonable alteratives to
litigation, including alternative dispute resolution procedures, such as mediation. HUD attenipts
to conciliate all Fair Housing Act complaints. In addition, it is the Department of Justices policy
to offer prospective defendants &c opportunity to engage in pit -suit settlement negotiations,
except in the most unusual eir+eumstances.
-15-
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• Passengers fm*t be at the daalgneled pile 10 minutes prior to dopaAus cw they may now to be aocommodsled on another
FrontierAilines flight.
• Tickets are non4ranallerrable.
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• Milan" changes may result in a change fee of up to a $100 and any applicable fare difile nce. Change two vary by Faro Option
purchased. Sea the Tess of your tore listed above.
• To file a compiment or complaint, Wait www .FlyFrahtieccdNCuatOffOMflalons or mail to: Aftw. CuMomsr hilarious, Frontier
Caller One, 7001 Tower Road. Denver. CO 80249
Illeve Was at the ah"rt: check in online within 24 hours of your departure.
o(7
5/15/13 7:46 AM
Gmail - Reservation Can6rmation hap:// mail. Swgic. com /maim?= 2&lk-- M7'64dfgdtview=pt..,
Want Hero boroomT Vlla have ItI STRETCH seating is now available on all Airbus and E190 atrcraR. Learn More.
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Is(pl abws ayndroats ckgabbuae®prnail.00m> Fri, May 3.2013 at 7:12 AM
To: Jason Huller c)dhuflbr&vaallc corn>
Flare b Are plane tic for me to go to FL 1 am faeHng two ways - t will have to get to Denver but Chris can drive me If you soft
Dr. Karol Kellar
AsnociaM F' OW= King Univ.
Counseling and Forensic Psychology
W lit Marriage FanrNy Therapist
ADA Tito 11 and Title III Specialist
www.equelaccessadvoceles.com
702 - 528-9588
NOW AVAILABLE -
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IMP abuse syndnoias cieg mMl,eown> Fri, May 3, 2013 at 139 PM
To: Frontier PJdkv s eno.neply0ftfirpntler >
com
Okay._ 1 we you booked me for a week. That dwuld be good. I Will start to gat ready.
I could use a dirt If you cant And a vvfmalchair. Club are Man rented for a period of lima. I need *rim anyway tf I Could get one that
COMA apart wally to In rtaport. Mile will work something out. Kwon should have one he could ban you for s day or so.
You have Mile tendency to pick me up and make me go places OW 1 don't think I on.
I love you. Amdous to am you.
Mom
faww rrosi+leeap
Dr. K win Huller
Assoeials pfohow Kings UMv.
Counseling and Forensic Psydrology
NV tic Marriage Family Therapist
ADA Title 11 and Title III Specialist
www.oquidaccessedwo"fs.can
702 -528 -9588
NOW AVAILABLE -
If you have a disability, dent 90 10 oera't without (/Irlockfig Jastfaa - your guide for protection under the Americans with
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f>abnastar®rlatcom 0 posimasten)�QsLcorn> '
To: iegalsbuea®gmall.com Fri. May 3, 2013 at 1:39 PM
of 7
5115113 7.46 AM
3mail - Reservation Confirmation https: // mail. 900910. nom/ anaiV hii= 2&ik- fBS7764df9&view-pt...
Delivery has failed to these recipients or distribWon lists:
Frontier Air firms
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Date: Fri, .3 May 2013 13.319:51 -0600
Hsasags -ID: aCJ+ glwLYPoutLAcy00pt3McTW4UNbpsi92r8rrbvb96urQNe CfABmail.gmail.cama
Ssbjeat: ties Reservation Confis*Mti0a
rrcas legal abuse, ayndr0 cI&gaI&buGe @gmaiI.ccn>
To: P7r Airlines <no- replyfiflyfrcntier.com>
Content -Vjpae multipart/alternative; boundary •4)89e0115r3fOb907f304dbd58367'
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Fof7
5/15/13 7:46 AM
Gmail - Reservation Confirmation bads:// maii-goojbxortL/mail /?ui= 2&ik- -M7764dP9&view =pt...
Action: hied
Status: 5.1.1
OlegnosiIC-Code: tr 0.550 5.1.1 RESOLVER.ADRRecipNotFound: not loud
X- Display -Name: Frontier Airlines
Forwarded message --
From: "I abuse syndrome c"lmbu"ill?9ma8.cW;o
To: FronierAiANfrls <rko{s"8ylrontieroom>
Cc
Date: Fri, 3 May 201313:39.51 -0600
Subject: Re: Reservation Conflrrmdon
Okay. 1 ase you booked me for a week That could be good. 1 Coll start b get ready.
I Could Iree a Carl if you can111nd a wheelchair. Carts are often fantod for a period of erns. 1 need one anyway If 1 Could get one that
comes apart eerily to Uansp04 V* vA work 00 sift ouL Kavon should have one he could loan you ter a day or so.
You have this tendency b pick me up and make me go places that I donl think 1 can.
I love you. Aru6ous to see you.
Mom
On Thu. May 2.2013 at 8:45 PM, Frontier AlrWas <no-reOyWmnt;er.com> wrote.
i FronOwAkOmes Inc.
{ 7001 Tower Road
Dan~. CO 80249 -7312
Thank you for choosing FWronder corn for you trawl plans. Please read these Nnport M details Ctwsfuff regardNg your purchase
and Itinerary:
Booking Confirmation
Reeeroetion Code: KGCOXC Main contact: Dr Karin Huffer
Issue Dale: Thu. 02 May 2013 E- rural: jordenemowwoup.Com
Hance phone: 9544;467447
Passengers
or KtAn Huffer Fllght DENfLL. FLL-DEN
3PO" Request Meet And AGLOW reelchatr For Ramp
To" Number 4222175174798
Seat 25C,25C
Air Itinerary Details
Flights
Deaver CO (DEN). US Fort Laudsrda4Mollywood FL (FLLh US F8 382 Fare T
Tue. 14 May 2013, 03:46 PM Tue. 14 May 2013, 09.33 PM Frontier 0 IrW Classic
Airbus 300. Airlines Inc
Fort Lt dardslalNolrwood F4 (FLL). US Denver CO (DE"L U6 F9 835 Fare Type: Classic
Mon, 20 May 2013, 00:48 AM Mon, 20 May 2013. 11:86 AM Frontier 0
Airbus M. Airlines fns
Fars Breakdown
Passenger Type Base Fan Tans Total Fan Number at Total Fame
of 7
5/15/13 7 -46 AM
3mail - Reservation Confirmation https:// malt. gooSle. oom / malt ?ui- 2&ik= fBS7764df9&view=pt...
pw person PK person pK pion possongee
Adult 258.74 USD 41.00 USD 207.80 USD x 1 207.80 USD
DEN4FLL: Close le rare aww is
I. Advance Seat Assignment': SELECT Sea"
2. Clhsdwd Baggage (2 bags): Included
3. Sartre OW Slandby: Included
4. Some Day Confirmed Alhunste Flight =25
S. Itinerary Change Fee prior to day of trawl: $0 + rare difference
6. Now Charge Fee. $50; fare Allerence
7. STRETCH SeMiig•': From $5"gmw t
8. SELECT Seating': Included
9. EaryRNumol9 Credit 3 Eke Qualification Mles: 125%
10. • Not available on Great Lakes codsshare flights.
11. " Classic STRETCH pricing available if puridrased prior to boarding; Economy STRETCH pricing will apply 4 purchased orhboard.
FLL#N: Clwsie Fan Bandits
1. Advance Seat Assignnwnt': SELECT Sealing
2. Chadhed Boggs" (2 bags): Included
3. Same Day Standby- included
4. Sarre DayConfrmad Altsmste Fight: $25
5. Ulnerary Change Fee prior to day of travel: $0 + fare diftra oe
6. Name Change Fee: $50 +rare dtference
7. STRETCH Seating": From SShegment
8. SELECT Seating Included
9. EarlyRsAramg CnmM 6 Me QuatiOwYon NNles. 12571
10. ' Notsvailable on Great takes cod"hors Mottle.
11. •• Classic STRETCH pricing available If purchased prior to boarding; Economy STRETCH pricing will apply if purchased onboard.
GRAND TOTAL
Charged to American Express »..1003
TOTAL: 497.00 U'0
Delivery Information
Dslvery Opllon: E- Ticket
Important information .
Be sure to review what's included in your Fare Type before wdvkq at to airport. CLICK HERE for fare Wribulos.
To assist with your travel planning:
• We allow each passenger. 1 Of charge, one carry -on bag (up 10 9.1r height x 15.5" width x 24• length and 35 pounds) and one
Personal item. Vish our carry-on baggage page for details.
• 1st and 2nd if i An baggage is" vary based on the Fare Oplion purchased. See the fees and bww is of your fare laled
above. For all Fare Options, for travel through July 10. 2013. here is a $50 fee for each bag beyond the Bret IM chocked bags.
For licketa purchased on or Miler February 17, 2013, for travel on or alter July 11, 2013, ow tae is $75 for each bag beyond the
first two checked baps- Any bog that exceeds 62 linear inches (up 10 a maximum of 110 linear inches) veil incur a $75 oversize
fee. Any bag Viet exceeds 50 pounds (up We maximum of 100 pounds) will incur a $75 overweight tee.
Ascent and Summit EidyRetumse members receive two complimentary cocked bags on all Fare Options. Active duty rnBany
members wMh 10 (not including family members ortravelig companions) will not be assessed beg fees. Meths personnel with ID
may check bps and equipment for $25 each.
• Itineraries may be canceled without ire penatkis for nesotvations booked within the past 24 hours.
• Basic, Economy, and Classic ticket must be aneelled or charged prior to the scheduled depanuro time to retain ticket value.
• Frontier reconvnends that your arrive at the airport at least two hours prior to your scheduled departure tme.
• Passengers are required to have ter bearding pass In hand 30 minutes prior to departure fordomealic flights and 00 mirmles for
Intonational lights in order to allow sulltderrt tims to class sipoA security; athervvise, they may reed to be accommodated on
another Frontier Airlines Bight.
i of 7
5115/13 7:46 AM
Gmail - Reservation Confirmation bttps://m d.googler corn /maiU?ui- 2&ik=MS7764df9 &view
• Passengers must best the designated gate 10 minutes prior to departure or they my need to be scoom modaled on another
Frontier Airlines flight.
• Tide is are non- translsrrable.
• TICkets are non - refundable unless othervAse epacitisd.
• llinersry ch nges may result in s change fee of up to a $100 and arty spplicsbk faro dMarance. Change tees vary by Faro Option
Purchased. See the lass of your tare listed above.
. to file a oWWWnenl or ComPISK visit www. FlyFronkr.cordCustomerRelations a mall to Ann: Cuetwor RslalloW Frondsr
Canter One. 7001 Tower Road. Denver; CO 60249
Save firm at the mlgmrt: cheek in online wiMftn 24 hours of your departure.
Want more Iproom7 We have MI STRETCH seating is now available on all Akbus and El 90 aircraft. Loam Mors.
Book wtlh sar6denos: Mb guarantee Mist you'll Ind Frontiers best value N FyFronler m with our Best Fare Guarantee.
Renal Cars: Choose tom Avis or Budget, ON from ors easy sasrrhl Rent a Car. Book Now.
Frbr*Jw tM@MrCar4: Apply for the Frontier Master Card® today and earn rip to 20,000 miles! Terns and Conditions apply. Learn Mare.
Frontier Aidkms www.FlyFrontier.com
Dr. Karin Hinter
Associate Professor King's UnW .
Counseling and Forensic PWdiokW
NV lic Marriage Family Therapist
AGA Title N and Tllle III Specialist
www.equsiwmsssdvocates.com
.T02- 528 -91588
NOW AVArl.ABLE -
2f tae hove a disability, don't go to court without lMaddry Jusfke -your Wicle for prdedlon under the Americans with
Deabiitles Ad Amendments Ad (ADAM) at www.equakmnsadvocates.com
rof7
511913 7:46 AM
Confidential FAX Coversheet
Date: 5-15-13
To: TOWN OF HIGHLAND BEACH (Attention Valerie - FAX 561 -265 -3382)
BOARD OF ADJUSTMENT & APPEALS
561 -265 -3562
FAX NUMBER
FrOM Dr. KARIN HUFFER
khuffeMLVAA11c.com
702-520-9586
FAX 561423 -6257
RE: Declaration of disability for today's hearing
Pages: 16
Note if misdelivered.
In the event this material is delivered to the wrong address. please respect the confidentiality by returning it
to the sender and destroying any residual data
Town of Highland Beach
3616 South Ocean Blvd.
Highland Beach, FL 33487
Re: Request for side yard setback variance at 4210 S. Ocean Blvd., Unit #3
Highland Beach, FL 33487
To Whom It May concern:
My name is Al2 IzUg G/ and I reside at
am a neighbor of Jordan
Huffer, the property owner making the above referenced request. I have
reviewed the plans for the proposed addition and I support project. I feel that
under Mr. Huffer's special circumstances, his request for this variance should be
granted.
Sincerely,
Town of ftdand Beach
3616 South Ocean Blvd.
Highland Beach, FL 33483
I
I
I
Re: Request for side yard setback variance at 4210 S. Ocean Blvd., Unit #3
Highland Beach, FL 33467
To Whom It May Concern.
M name is "j� ` and 1 reside at
I am a neighbor of Jordan
Huffer, the property twrmer making the above mferer"d request. I have
reviewed the plans for the proposed add ition and i support project. I feet that
under Mr. Buffer's special circumstances, his request for this variance should be
granted.
Sincerely,
Town of Highland Beach
3616 South Ocean Blvd.
Highland Beach, FL 33487
Re: Request for side yard setback variance at 4210 S. Ocean Blvd., Unit #3
Highland Beach, FL 33487
To Whom It May Concern:
My name is l L t/l-�- and I reside at
' S�v /rn a neighbor of Jordan
Huffer, the property owner making the above referenced request. I have
reviewed the plans for the proposed addition and I support project. I feel that
under Mr. Huffer's special circumstances, his request for this variance should be
granted. ,
Sincerely
Comments of Joseph Frost, Owner
4210 South Ocean Blvd, Unit 2
Board of Adjustment Hearing
May 15, 2013
1 own Unit 2 of the building where the applicant wishes to modify and encroach
into our side yard and setback. I am here today to strongly oppose the requested
variance and in fact oppose any modification to our building for the following
reasons:
I have read our town ordinances pertaining to variances and I have also read the
applicant's responses to the four required stipulations for approval of such a
request.
I offer the following for your consideration:
With respect to reauirement 4A — Special Conditions — there are no special
conditions associated with this property, merely typical easements and setbacks
that apply to all buildings in the town for the purposes of protecting residents and
neighbors, future maintenance and access and green space for the enjoyment of
all.
With respect to requirement 4B — Circumstances not tied to actions of the
applicant - While not tied directly to actions of the applicant, the applicant agreed
to the conditions set forth in both town ordinance and our condominium
declarations when he purchased the property. He is now being asked to honor
the stipulations of purchase.
With respect to reauirement 4C — Special Privilege: The applicant is requesting
to build across property, which he does not solely own and into an easement that
is there for the reasons indicated in the response to item 4A. While I understand
and applaud the applicant's desire to take care of his mother, the end in this case
does not justify the means. This is a condominium with multiple owners not a
single - family home. We have a small amount of green space and an already
restricted side yard access, further diminution of that area is unacceptable.
Further, granting a variance to extend this request into the setback would clearly
constitute a special privilege to the applicant and a penalty to the other owners
and our neighbors.
F
With respect to requirement 4D — Literal Interpretation and derivation of rights -
The test for this requirement is that existing conditions must not deprive the
applicant of rights "commonly enjoyed by others". This is not a common request
nor does an extreme and extenuating circumstance exist here. This variance
request and ultimately the permit itself rest on implications of financial hardship to
the applicant. There are numerous other remedies available to the applicant to
address his family's needs without impacting our side yard or infringing on the
side set back. As an example, I purchased a unit down on Bel Air Rd specifically
to address this issue for my aging parents.
In closing, I will share with you that this variance request and the development
action in general is prohibited by our condominium declarations.
• As we each own fee simple an undivided interest in the Common Areas;
and
• That no owner shall make any alterations in Common Elements or
interfere with any easement and
• That "Common Elements shall remain undivided and no owner shall bring
any action to partition"
While these controls lie in the civil arena, they are at least in part why I
purchased at 4210 and any action by the Town contrary to these stipulations will
send the wrong message to the applicant and potentially other residents.
Also, for the record, I hold a copy of an email sent to me last night from Mr. Alan
Teller, Owner of Unit 1 of our building which states the he "objects to the request
for the variance". This email would appear to make it unanimous across the most
effected parties, the owners of 4210 and our neighbors at 4206, that no one is in
favor of this variance request.
Thank you for the opportunity to speak.
From: mstboat < mstboat @bellsouth net
Date: May 14, 2013, 8:42:53 PM EDT
To: JB Frost < jbfrostlna bellsouth net
Subject: Re: scan
As I have stated all along: Since our unit has an extension I cannot
object to the application for an extension. I object to the request for
the variance.
---1
Alan Teller
From: JB Frost < ibfrosticd)belisouth net
To: mstboat < mstboatftellsouth net
Sent: Tue, May 14, 2013 8:23:01 PM
Subject: Re: scan
Do you support the variance? Yes or no?
.TB
JB Frost, CEO
Alliance International Development Group