{"id":442,"date":"2026-01-14T12:00:00","date_gmt":"2026-01-14T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=442"},"modified":"2026-01-14T12:00:00","modified_gmt":"2026-01-14T12:00:00","slug":"saitta-greystar-fha-1985-conspiracy-tenant-claims-dismissed","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=442","title":{"rendered":"Saitta v. Greystar Real Estate Partners \u2014 S.D. Cal. Dismisses Tenant’s FHA and Civil-Rights Conspiracy Claims Against Apartment Owners"},"content":{"rendered":"
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Case<\/dt>\n
Saitta v. Greystar Real Estate Partners, LLC<\/dd>\n
Court<\/dt>\n
U.S. District Court \u2014 Southern District of California<\/dd>\n
Date Decided<\/dt>\n
2026-01-14<\/dd>\n
Docket No.<\/dt>\n
3:25-cv-01135<\/dd>\n
Status<\/dt>\n
Unreported \/ Non-Citable<\/dd>\n
Topics<\/dt>\n
Fair Housing Act, 42 U.S.C. \u00a7 3604(b), Section 1985 conspiracy, supplemental jurisdiction declination, landlord-tenant<\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

Laura Saitta is a tenant at the One Paseo Village apartment complex in San Diego. Acting without counsel, she sued the building’s owner Kilroy Realty, the management companies (Greystar entities), and several of their executives, alleging a wide range of landlord-tenant problems involving washer\/dryer issues, repair requests, disputed rental charges, neighbor disputes, and a Notice to Pay Rent or Quit. She framed her federal hooks as a Fair Housing Act sex-discrimination claim and a \u00a7 1985 conspiracy-to-interfere-with-civil-rights claim, with 19 California state-law claims piggy-backed on supplemental jurisdiction.<\/p>\n

This was the third time around. The court had already dismissed her First Amended Complaint with leave to amend. The Second Amended Complaint repeated the federal claims and the same general theory, prompting another motion to dismiss.<\/p>\n

The Court’s Holding<\/h2>\n

The court granted the motion to dismiss as to all federal claims and declined supplemental jurisdiction over the state-law claims.<\/p>\n

On the FHA claim, 42 U.S.C. \u00a7 3604(b) prohibits discrimination in the rental of a dwelling because of race, color, religion, sex, familial status, or national origin. The complaint alleged “discriminatory pricing” and refusal to rent two-bedroom apartments “based on the fact that she is a woman.” But the supporting facts contradicted those conclusions in important ways. The general manager Saitta blamed for the alleged actions was herself a woman, undermining the inference of gender-based animus. The Kilroy CEO Saitta blamed for failing to address her complaints \u2014 Angela Aman \u2014 was also a woman. And Saitta’s own pleading admitted that she was renting a two-bedroom penthouse unit, contradicting her claim that women were forced into one-bedroom apartments. The court would not credit conclusory allegations of discrimination unsupported by, and partly contradicted by, the alleged facts.<\/p>\n

On the \u00a7 1985 conspiracy claim, the law requires both factual specificity about an alleged conspiracy and an “invidiously discriminatory animus” \u2014 typically race-based or class-based. Because the conspiracy claim was “inextricably intertwined” with the failed FHA claim and rested on the same underlying allegations of gender-based animus, the conspiracy claim failed for the same reason.<\/p>\n

With both federal claims dismissed, the court exercised its discretion under 28 U.S.C. \u00a7 1367(c)(3) to decline supplemental jurisdiction over the 19 California state-law claims. The Supreme Court’s United Mine Workers v. Gibbs<\/em> direction \u2014 that state claims should be dismissed when federal claims fall before trial \u2014 pointed in the same direction.<\/p>\n

Key Takeaways<\/h2>\n