MEYER v. HOLLEY

Print this Page
Case Basics
Docket No. 
01-1120
Petitioner 
Meyer
Respondent 
Holley
Advocates
(Argued the cause for the petitioner)
(Department of Justice, argued the cause as amicus curiae, supporting the respondents)
(Argued the cause for the respondents)
Tags
Term:
Facts of the Case 

The Fair Housing Act (FHA) forbids racial discrimination in respect to the sale or rental of a dwelling. The Holleys, an interracial couple, alleged that a Triad real-estate corporation sales representative prevented them from buying a Triad-listed house for racially discriminatory reasons. The Holleys filed suit against the sales representative and David Meyer, Triad's president, sole shareholder, and licensed "officer/broker," claiming that he was vicariously liable for the sales representative's unlawful actions. The District Court dismissed the claims, stating that the FHA did not impose personal vicarious liability upon a corporate officer or a "designated officer/broker." In reversing, the Court of Appeals ruled that the FHA imposes strict liability principles beyond those traditionally associated with agent/principal or employee/employer relationships.

Question 

Does the Fair Housing Act impose personal liability without fault upon an officer or owner of a residential real estate corporation for the unlawful activity of the corporation's employee or agent?

Conclusion 
Decision: 9 votes for Meyer, 0 vote(s) against
Legal provision: Fair Housing

No. In a unanimous opinion delivered by Justice Stephen G. Breyer, the Court held that the FHA does not impose liability without fault upon the employer in accordance with traditional agency principles. In other words, the FHA normally imposes vicarious liability upon the corporation, but not upon its officers or owners. In the absence of a clear indication of congressional intent to abrogate the common law principles of vicarious liability, the Court reasoned that neither the right of the officer to control the salesperson nor the overriding societal priority of the FHA's objectives warranted extending tort-related vicarious liability rules to include the officer. The Court also reasoned that nothing in the FHA supported imposing a non-delegable duty upon the officer to ensure that its salesperson did not discriminate.

Cite this Page
MEYER v. HOLLEY. The Oyez Project at IIT Chicago-Kent College of Law. 20 June 2014. <http://www.oyez.org/cases/2000-2009/2002/2002_01_1120>.
MEYER v. HOLLEY, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2000-2009/2002/2002_01_1120 (last visited June 20, 2014).
"MEYER v. HOLLEY," The Oyez Project at IIT Chicago-Kent College of Law, accessed June 20, 2014, http://www.oyez.org/cases/2000-2009/2002/2002_01_1120.