Lillian Gonzalez Plaintiff— v. 2009 Houston Scott Street, L.P., doing business as Austin Development Lots; Rene O. Campos; Marcus Dominic; Eureka Multifamily Group, L.P.; Kristy O. Neil Defendants—
July 20, 2026·25-20419·Per Curiam·By Aisha Johnson
The Fifth Circuit affirmed summary judgment for landlords sued by a Section eight tenant alleging housing discrimination and retaliation.
Gonzalez lived in subsidized housing where her daughter was assaulted. She requested a transfer which was denied. She alleged VAWA and Fair Housing Act violations after a neighbor dispute led to a withdrawn eviction notice.
The court’s reasoning
The court held VAWA has no private right of action. FHA claims lacked evidence of discrimination or sufficient retaliation. Section nineteen eighty-three claims failed as landlords are not state actors. State law claims failed due to lack of outrageous conduct or eviction.
What it means going forward
Private landlords are insulated from VAWA and Section nineteen eighty-three liability for housing disputes.
