Background
Emmanuel Adeyinka appealed pro se from a district court judgment dismissing his action alleging federal and state law claims arising from his residence at a temporary alternative shelter site.
The court’s reasoning
The Ninth Circuit reviewed the district court’s dismissal de novo. The court affirmed because Adeyinka failed to allege facts sufficient to show discrimination or retaliation under the Fair Housing Act. The court also affirmed the dismissal of his Fourteenth Amendment claim because he failed to allege facts sufficient to show a violation of his right to procedural due process. Finally, the court affirmed the dismissal of his breach of contract claim because he failed to allege facts sufficient to show the existence of a contract or detrimental reliance.
What it means going forward
The decision reinforces that pro se plaintiffs must allege specific facts to survive dismissal in housing discrimination and due process cases within the Ninth Circuit.
Podcast (federal-narrative-summaries): Play in new window | Download