Yesterday a federal appeals court upheld a $100,000 punitive damage award for a tenant in an Arlington high-rise whose lease was not renewed because of her persistent complaints about her allergies to smoke, mold and paint fumes.
Plaintiffs Linda and Domenic Matarese sued Smith Property Holdings, the owner of Archstone Pentagon City in Arlington, management personnel and the apartment complex’s management company, alleging fair housing violations under state and federal law. After a six-day trial, U.S. District Judge Gerald Bruce Lee decided the case for the tenants last May.
In addition to the punitive damages award based on the conduct of a particular manager, Lee awarded the tenants injunctive relief. He also awarded compensatory damages of at least $17,318.50 for overpayment of rent and $50,000 for Linda Matarese and $1,000 to Dominic Matarese, for their emotional distress.
In an unpublished opinion released Feb. 28, a 4th U.S. Circuit Court of Appeals panel said the district court did not err in finding that Archstone regarded Matarese as having such an impairment, even though she actually did not. Nor did the district court err in awarding punitive damages, given Archstone’s treatment of the Matareses, the panel said in Matarese v. Archstone Communities.
But the panel vacated the district court’s award of injunctive and equitable relief, which it said was unnecessary, as it only required Archstone to follow the law it is already required to follow.
By Deborah Elkins