Predetermination Settlement Agreement Sample Contracts

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • April 24th, 2017

Complainant is a member of the Iowa Civil Rights Commission (hereinafter referred to as the Commission). As a member, Complainant has the authority to file a complaint alleging a discriminatory practice in violation of the “Iowa Civil Rights Act of 1965,” Iowa Code Chapter

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PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • July 25th, 2019

Description of the Parties: Complainant is a member of the Iowa Civil Rights Commission (hereinafter referred to as the Commission). As a member, Complainant has the authority to file a complaint alleging a discriminatory practice in violation of the “Iowa Civil Rights Act of 1965,” Iowa Code Chapter 216. Complainant alleges discrimination in the area of housing on the basis of disability. Complainant alleges Respondents failed to provide a reasonable accommodation by refusing to waive their “no-pets” policy for a large assistance animal and this resulted in different terms, conditions or privileges of rental, and a denial of rental housing based on disability.

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • November 17th, 2017

A complaint having been filed by Complainant against Respondents with the Commission under Iowa Code Chapter 216 and there having been a preliminary inquiry, the parties do hereby agree and settle the above-captioned matter in the following extent and manner:

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • August 8th, 2016

Complainants allege discrimination in the area of housing on the basis of familial status. Complainants allege, on November 19, 2015, Respondent Noreen Gingerich showed Complainant Maria Alarcon a one-bedroom apartment. Upon learning there was an additional vacant unit across the hall from that first unit, Complainants’ daughter-in-law expressed an interest in the second unit for her family. Complainants allege Respondent Gingerich was enthusiastic about renting to both families until she learned their daughter- in-law and husband had three minor children and Complainants would be providing child care for one grandchild during the day. Complainants further allege, on November 21, 2015, Respondent Gingerich told Complainant’s daughter-in-law that she would not rent to either family and stated, “It isn’t going to work out because of your children.” Complainants allege they were denied rental and subjected to a discriminatory statement based on familial status. Respondents own and manage

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • August 8th, 2016

Complainant alleges discrimination in the area of housing on the basis of disability by association. Complainant alleges she and her roommate made an offer to purchase a condominium contingent upon Respondents allowing her 18-pound pet dog and her roommate’s 75-pound service dog. By refusing to waive their “one dog, 35-pound” policy for her roommate’s assistance animal, Complainant alleges Respondents failed to provide a reasonable accommodation, which resulted in a refusal to sell and in different terms and conditions of sale based on disability. Respondents deny having discriminated against Complainant, but agree to settle this claim in the underlying action by entering into this Predetermination Settlement Agreement. The subject property is a 12-unit condominium complex, Hickory Grove, located at 420 First Avenue #208, Iowa City, Iowa 52245.

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • December 14th, 2018

Description of the Parties: Complainant alleges discrimination in the area of housing on the basis of disability. Complainant alleges Respondents failed to properly investigate complaints and take prompt action to end other tenants’ disability-based harassment toward her. In addition, Complainant alleges after she made harassments complaints, Respondents retaliated against her and held her to different discipline standards for alleged noise complaints and violations of their rules compared to other persons without disabilities, and Respondents subsequently terminated her tenancy. Respondents deny having discriminated against Complainant, but agree to settle this claim in the underlying action by entering into this Predetermination Settlement Agreement. The subject property is a five-unit apartment complex located at 210 West Iowa Avenue, Indianola, Iowa 50125.

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • August 19th, 2020

Description of the Parties: Complainants allege that Complainant Angela Bishop is a person with a disability who has an assistance animal. The symptoms of her disability are mitigated through gardening and that her assistance animal is a part of that therapy, which include having the animal outside while she is gardening. A tie-out for her assistance animal would facilitate this, as Ms. Bishop is not able to hold the animal’s leash while engaging in gardening. Respondent denied Complainants’ request to waive the policy prohibiting tie-outs as an accommodation for Ms. Bishop’s disability. Complainants allege Respondents’ refusal to waive their “dog tie-out” policy for an assistance animal constitutes a failure to make a reasonable accommodation and has resulted in different terms and conditions of homeownership based on disability.

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • August 8th, 2016

Complainant is a member of the Iowa Civil Rights Commission (hereinafter referred to as the Commission). As a member, Complainant has the authority to file a complaint alleging a discriminatory practice in violation of the “Iowa Civil Rights Act of 1965,” Iowa Code Chapter

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • April 9th, 2019

Description of the Parties: Complainant alleges discrimination in the area of housing on the basis of disability by association through intent to live in the subject rental. Complainant alleges his girlfriend is a person with a disability who needs an assistance animal. Complainant alleges Respondents failed to provide a reasonable accommodation by refusing to waive their “no pets” policy for his girlfriend’s assistance animal and this resulted in different terms, conditions or privileges of rental, and a denial of rental housing based on disability. Respondents deny having discriminated against Complainant, but agree to settle this claim in the underlying action by entering into this Predetermination Settlement Agreement. The subject property is a single family dwelling located at 225 9th Street SE, Sioux Center, Iowa 51250. The subject property is currently in the possession of tenants holding a leasehold interest based on a valid month-to-month tenancy.

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • March 31st, 2016

Complainant and his adult son are persons with disabilities who require the use of assistance animals. Complainant alleged Respondents refused to waive their no-pet policy to allow them to have assistance animals, which resulted in different terms and conditions of rental based on disability. Respondents own or manage the subject property, a rental duplex located at [Address Redacted].

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • December 14th, 2018

Description of the Parties: Complainant alleges discrimination in the area of housing on the bases of race and retaliation. Complainant alleges Respondents failed to take action to stop race- based harassment and subsequently served her with a notice terminating her tenancy in retaliation for exercising her right in requesting Respondents stop on-going race-based harassment.

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • July 21st, 2021

Description of the Parties: Complainant is a person with a disability. Complainant alleges Respondent Caroline Grieder, former Executive Director of Respondent, refused to permit a reasonable modification to Complainant’s kitchen counter. The subject property is a multi-unit apartment building located at 201 N. 25th St., Council Bluffs, IA 51501.

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • May 31st, 2016

Complainant is a member of the Iowa Civil Rights Commission (ICRC). As a member, Complainant has the authority to file a complaint alleging a discriminatory practice in violation of the “Iowa Civil Rights Act of 1965,” Iowa Code Chapter 216. Complainant alleged Respondents designed and constructed covered multifamily dwelling units in violation of the design and construction accessibility requirements of the Iowa Civil Rights Act (ICRA) and the federal Fair Housing Act (FHA). Complainant alleged Respondents violated the “accessible route into and throughout the unit” and the “light, switches, thermostats, electrical outlets in accessible locations” requirements of the ICRA and FHA.1 Complainant specifically alleged, in Units 4100 and 4207, 1414 Adventureland Drive NW, Altoona Towers, (1) the exterior height of the threshold level was 5 inches, which is greater than the maximum allowable threshold height of 4 inches; and (2) the height of the thermostat controls was 55 inches, which is

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • February 2nd, 2018

Description of the Parties: Complainant alleged Respondents refused to process their Section 8 paperwork and subsequently tried to evict them due to their race (African American) and/or his disability. Complainant also alleged Respondent tried to steer him and his mother from an affordable, well-maintained apartment to a run-down, less desirable property due to their race and/or his disability. Respondents deny discriminating against Complainant and his mother, but agree to settle this complaint by entering into this Predetermination Settlement Agreement

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • January 9th, 2018

Description of the Parties: Complainant alleged Respondents failed to provide a reasonable accommodation for his assistance animal and this resulted in different terms and conditions of rental based on disability. Respondents deny discriminating against Complainant, but agree to settle this complaint by entering into this Predetermination Settlement Agreement (hereinafter

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • August 7th, 2017

Complainant is a member of the Iowa Civil Rights Commission (ICRC). As a member, Complainant has the authority to file a complaint alleging a discriminatory practice in violation of the “Iowa Civil Rights Act of 1965,” Iowa Code Chapter 216. Complainant alleged Respondents designed and constructed covered multifamily dwellings in violation of the design and construction accessibility requirements of the Iowa Civil Rights Act (ICRA) and the federal Fair Housing Act (FHA). Complainant alleged Respondents violated the “usable doors,” the “accessible route into and through the covered unit,” the “light, switches, thermostats, electrical outlets in accessible locations,” and the “usable kitchens and bathrooms” requirements.1

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • August 19th, 2020

Description of the Parties: Complainant is female. She alleges Respondent Baxter called her “pretty lady” on multiple occasions and asked if he could be her “sugar daddy,” and offered her money in exchange for sexual favors. Complainant reported these incidences to Respondents Lublin Properties, LLC and Heritage Property Management-AV, Inc., who investigated, but determined that it was a he said/she said scenario and nothing could be done. Complainant alleges Respondent Baxter’s conduct constitutes hostile environment sexual harassment and has interfered with her right to discrimination-free housing

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • June 5th, 2017

Description of the Parties: Complainant alleges discrimination in the areas of housing and retaliation. She claims, on November 4, 2016, she told Respondent Owner Christine Suchak that their rent check was late because she inadvertently sent it to the wrong address, she also reported that her fiancée was sexually harassed by Respondent Property Manager Mike Anderson on September 6 and 7, 2016. On or about November 14, 2016, Respondents served Complainant and her fiancée with eviction papers. Complainant believes Respondents terminated their tenancy in retaliation for exercising her right to oppose discrimination. Respondents own or manage the subject property, a single-family house, located at 633 West Lincoln Way, Marshalltown, Iowa 50158.

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • January 6th, 2022

Description of the Parties: Complainant is Romanian and a person with a disability. Complainant alleges he was subjected to discriminatory terms and conditions based on his national origin and disability. The subject property is a multi-unit apartment complex located at 2427 S Taft Ave, Mason City, IA 50401-6259.

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • May 22nd, 2020

Complainant is a member of the Iowa Civil Rights Commission (ICRC). As a member, Complainant has the authority to file a complaint alleging a discriminatory practice in violation of the “Iowa Civil Rights Act of

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • February 18th, 2016

Complainant is a member of the Iowa Civil Rights Commission (ICRC). Complainant alleged Respondents designed and constructed covered multifamily dwellings in violation of the design and construction accessibility requirements of the Iowa Civil Rights Act (ICRA) and the Federal Fair Housing Act (FHA).

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • November 30th, 2015

Description of the Parties: Complainant is a member of the Iowa Civil Rights Commission (hereinafter referred to as the Commission). As a member, Complainant has the authority to file a complaint alleging a discriminatory practice in violation of the “Iowa Civil Rights Act of 1965,” Iowa Code Chapter 216. Complainant alleged Respondents failed to provide a reasonable accommodation on April 10, 2015, by refusing to waive their “no-pets” policy for an assistance animal; and this resulted in different terms, conditions or privileges of rental, as well as a denial of rental housing based on disability.

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PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • February 28th, 2019

Description of the Parties: Complainant alleges discrimination in the area of housing on the bases of disability, race (African American) and retaliation. Complainant alleges she is a person with disabilities who needs an assistance animal. Complainant alleges Respondents implementation of a “no-pets” policy and refusal to waive it for her assistance animal constitutes a failure to provide a reasonable accommodation and this resulted in different terms, conditions or privileges of rental based on disability. Complainant also alleges the Caucasian tenants in the other side of the rental were allowed to keep their pets and this resulted in different terms, conditions or privileges of rental based on race. In addition, Complainant alleges Respondents served her with a seven-day notice to remove her assistance animal or vacate the subject property and this resulted in Respondents’ termination of her tenancy in retaliation for exercising her right in requesting a reasonable accommodation fo

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • August 16th, 2022

Description of the Parties: Complainant is a person with disabilities. Complainant alleges Respondents treated him differently than other tenants due to his disability status. Complainant also alleges that Respondents failed to make a reasonable accommodation for his disability, and retaliated against him after he made a request for reasonable accommodation. The subject property is a multi- unit apartment complex located at 1519 Grand Ave, Des Moines, Iowa.

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • January 6th, 2022

Description of the Parties: Complainant is African American and originally from Liberia. Complainant alleges Respondent failed to make timely repairs to his apartment because of his race and national origin. The subject property is multi-unit apartment complex located at 2120 Grand Ave, West Des Moines, IA 50265.

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • October 5th, 2016

Complainant alleges discrimination in the area of housing on the basis of disability. Complainant alleged Respondent failed to provide a reasonable accommodation by refusing to waive his 25-pound weight limit policy for her assistance animal, resulting in a refusal to rent and different terms and conditions of rental based on disability. The subject property is a 95- unit mobile home park, known as Colonial Estates, located at 1225 First Avenue NW, Mount Vernon, Iowa 52314.

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • May 22nd, 2020

Complainant is a member of the Iowa Civil Rights Commission (ICRC). As a member, Complainant has the authority to file a complaint alleging a discriminatory practice in violation of the “Iowa Civil Rights Act of

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • July 19th, 2021

Description of the Parties: Complainant is a person with a disability who requires the use of an assistance animal. Complainant alleges Respondents refused to waive their breed restriction policy for his assistance animal, resulting in a refusal to rent. The subject property is a single family house located at 1028 33rd Street NE, Cedar Rapids, IA 52402-3541.

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • August 7th, 2017

Complainant alleged Respondent failed to provide a reasonable accommodation by refusing to waive his “no-pets” policy for an assistance animal and this resulted in different terms, conditions or privileges of rental, and a denial of rental housing based on disability. Respondent owns or manages the subject property, a single-family home, located at 506 East Corning Street, Red Oak, Iowa 51566.

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • August 16th, 2016
PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • February 2nd, 2018

Description of the Parties: Complainants alleged Respondents failed to provide a reasonable accommodation for Complainant Ward’s assistance animal (cat) and this resulted in different terms and conditions of rental based on disability. Complainants also allege Respondents terminated their tenancy in retaliation for exercising their right in requesting a reasonable accommodation for Complainant Ward’s disability. Respondents deny discriminating against Complainants, but agree to settle this complaint by entering into this Predetermination Settlement Agreement (hereinafter

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • April 2nd, 2018

Description of the Parties: Complainant alleged Respondent failed to provide a reasonable accommodation by refusing to waive his “no-pets” policy for an assistance animal and this resulted in different terms and conditions of rental based on disability. Respondent owns and manages the subject property, a single family home, located at 1122 27th Street, Des Moines, Iowa 50311.

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • May 2nd, 2018

Description of the Parties: Complainant alleges discrimination in the area of housing on the basis of disability. Complainant alleges Respondents refused to waive their “no pets” policy for an assistance animal and this resulted in different terms, conditions or privileges of rental, and a denial of rental housing based on disability. Respondents own or manage the subject property, a duplex, located at 2 East Emma Avenue, Des Moines, Iowa 50315.

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • December 14th, 2018

Description of the Parties: Complainant alleged Respondents engaged in disability-based harassment and subjected him to different terms and conditions of rental due to his disability. Respondents deny discriminating against Complainant, but agree to settle this complaint by entering into this Predetermination Settlement Agreement (hereinafter “Agreement”). Respondents own or manage the subject property, a 50-unit apartment complex, known as Oakwood Manor, located at 311 N. 12th Street, Denison, Iowa 51442.

PREDETERMINATION SETTLEMENT AGREEMENT
Predetermination Settlement Agreement • April 24th, 2017

Complainant is a member of the Iowa Civil Rights Commission (hereinafter referred to as the Commission). As a member, Complainant has the authority to file a complaint alleging a discriminatory practice in violation of the “Iowa Civil Rights Act of 1965,” Iowa Code Chapter

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