Fair Housing Testing Round 2 Report Copyrighted
August 21, 2017
City of Dubuque Consent Items # 6.
ITEM TITLE: Fair Housing Testing Round 2
SUMMARY: City Attorney submitting information gathered from Round 2
of the Fair Housing Testing.
SUGGESTED DISPOSITION: Suggested Disposition: Receive and File
ATTACHMENTS:
Description Type
Staff Memo Staff Memo
THE CITY OF
DUB-�6 E MEMORANDUM
Masterpiece on the Mississippi
CRENNA M . BRUMWELL , ESQ.
CITY ATTORNEY
To: Mayor Roy D. Buol
and Members of the City Council
DATE: August 16, 2017
RE: Fair Housing Testing
Disability & Presence of Companion Animal
Background
Pursuant to an improvement package in the City Attorney's Office budget for FY2017 fair
housing testing was approved. The contract was awarded to the Fair Housing Center of
Nebraska and Iowa for two (2) rounds of fair housing testing which each consisted of
twenty (20) matched pair tests.
• Round 1 was based on race and included the addition of a Housing Choice
Voucher.
• Round 2 was based on disability and the presence of a companion/therapeutic
animal.
I have previously reported on Round 1 of the testing. In summary, there were thirteen
(13) tests where no evidence of discrimination was present. Seven (7) of the tests were
inconclusive which means there were some differences in treatment, but not enough to
file an administrative charge with the Iowa Civil Rights Commission.
Discussion
Round 2, which again was based on disability and the presence of a
companion/therapeutic animal, has been completed and the results received.
Of the twenty 20 tests com feted there were:
Test Dates Basis Determination
2/14/17 & 2/15/17 Disability No Evidence
2/14/17 & 2/15/17 Disability Inconclusive
11/8/16 & 11/9/16 Disability No Evidence
2/14/17 & 2/15/17 Disability No Evidence
2/14/17 & 2/15/17 Disability Inconclusive
2/14/17 & 2/15/17 Disability No Evidence
2/14/17 & 2/16/17 Disability No Evidence
2/14/17 & 2/15/17 Disability Inconclusive
2/14/17 & 2/16/17 Disability EVIDENCE
OFFICE OF THE CITY ATTORNEY DUBUQUE, IOWA
SUITE 330, HARBOR VIEW PLACE, 300 MAIN STREET DUBUQUE, IA 52001-6944
TELEPHONE (563)589-4381 /FAX (563)583-1040/EMAIL cbrumwel@cityofdubuque.org
2/14/17 & 2/15/17 Disability Inconclusive
3/7/17 & 3/8/17 Disability EVIDENCE
3/7/17 & 3/9/17 Disability No Evidence
3/7/17 & 3/8/17 Disability Inconclusive
3/7/17 & 3/8/17 Disability EVIDENCE
3/7/17 & 3/8/17 Disability Inconclusive
3/7/17 & 3/8/17 Disability EVIDENCE
3/7/17 & 3/9/17 Disability Inconclusive
3/7/17 & 3/8/17 Disability EVIDENCE
3/7/17 & 3/8/17 Disability EVIDENCE
3/7/17 & 3/8/17 Disabilitv No Evidence
Under determination, there are three (3) options which mean the following:
1 . "No evidence" means the testers were treated equally.
2. "Inconclusive" means there were some differences in how the testers were treated,
but not enough which would warrant the filing of an administrative charge with the
Iowa Civil Rights Commission.
3. "Evidence" indicates there was discrimination based on disability and the presence
of a companion/therapeutic animal.
Six (6) tests resulted in evidence of discrimination during Round 2 of the testing. The
tests revealed:
• Charging extra security deposit or non-refundable security deposit
• Charging an additional monthly fee
• Charging a cleaning fee
• Refusing to allow a companion/therapeutic animal.
Per the RFP, in the event testing indicated evidence of discrimination, complaints would
be filed with the Iowa Civil Rights Commission. The test results and supporting
documentation have been forwarded to the Iowa Civil Rights Commission for a
determination of whetherthey would like to file complaints for investigation and resolution.
Of note, this information will be reported to the U.S. Department of Housing and Urban
Development (HUD) as part of the Voluntary Compliance Agreement (VCA) reporting.
Additionally, I will be using the test information labeled "inconclusive" and "evidence" in
the fair housing section of the Successful Rental Property Management Program. Staff
will seek opportunities to further discuss legal parameters and implicit bias with landlords
and property managers.
Conclusion
This testing based on race and disability has offered important data which can be used in
development of the City's Annual Action Plan under the VCA and 5-year plan prepared
by the Housing & Community Development Department.
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Request
This memo is informational and can be received and filed for City Council action.
cc: Michael C. Van Milligen, City Manager
Kelly Larson, Human Rights Director
Alvin Nash, Housing & Community Development Director
Erica Haugen, Community Development Specialist
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