Bank of America Corp. v. Miami

Under the FHA § 3602(i), a City constitutes an “aggrieved person” and may bring suit under that section. Further in an action under the FHA, a plaintiff must prove a direct relation in order to show “proximate cause,” which requires more than mere foreseeability.

In 2013, Respondent brought two suits in federal court against Petitioners claiming that Petitioners engaged in discriminatory and “predatory” lending practices with minorities as opposed to other persons who were similarly situated. The district court dismissed the complaints determining that: 1) the harms alleged fell outside the “zone of interests” protected under the FHA, 2) the complaints failed to prove causation, and 3) the complaints failed to allege criminal activity that occurred within the statute of limitations. Respondent amended its complaints and sought reconsideration. However, the court found that that only resolved the statute of limitations issue and declined to reconsider. Respondents then appealed and the Eleventh Circuit reversed determining that the plaintiffs had adequately plead proximate cause and that the actions were within the “zone of interests” that the FHA was meant to protect. The U.S. Supreme Court granted certiorari in order to decide whether the amended complaints satisfied the FHA’s requirements for “zone of interests” and proximate cause. The Court first determined that the financial injuries felt by the City because of these discriminatory and “predatory” lending practices were sufficient to qualify them for the FHA’s “zone of interests.” Further, the Court determined that the Eleventh Circuit erred by determining that the proper standard of proximate cause was foreseeability. Instead, a plaintiff must show a direct relation between the injury felt and the conduct alleged in order to collect under the FHA. VACATED and REMANDED.