Commission on Human Rights and Opportunities v. Peterson
Plaintiffs who allegedly suffer emotional distress, because a landlord informs other tenants that the plaintiffs receive Section 8 assistance, and because the landlord calls them "bi---" and accuses them of "scamming," can be entitled to damages for emotional distress and punitive damages. Alyssa Peterson reached agreement with John and Ann Beaulieu to lease the subject premises between September 2008 and August 2009. The Beaulieus became disabled and obtained Section 8 assistance. On March 23, 2009, Peterson sent the Beaulieus a letter and complained that they paid the rent late and manufactured excuses. "Perhaps what is most tragic," wrote Peterson to the Beaulieus, "is that your penchant for exaggerating, lying or scamming your way through life via living off others, government benefits or lawsuit proceeds, has now trickled down and 'infected' the next generation." The Beaulieus allegedly suffered emotional distress, because Peterson considered them to be "scammers." Soon after, an inspector from Housing and Urban Development inspected the premises and ordered Peterson to correct violations. On June 20, Peterson allegedly called Ann Beaulieu a "bi---" and informed the Beaulieus that because they had permitted the HUD inspector to visit the basement without Peterson's permission, they no longer could use the basement. Peterson allegedly informed the other tenants that the Beaulieus received Section 8 assistance, which embarrassed the Beaulieus. The Beaulieus claimed that Peterson arranged to stop the heat, and that they required it even during the summer. One month before their lease expired, the Beaulieus arranged to lease another apartment that cost $150 more per month. The Commission on Human Rights and Opportunities sued Alyssa Peterson and alleged that she discriminated against the Beaulieus, because of their source of income. Peterson objected that the Beaulieus allegedly paid their rent late and lacked a legitimate excuse. The Beaulieus proved that Peterson was recklessly indifferent to their rights. The court found that the Beaulieus were entitled to $5,000 in punitive damages, $10,000 for emotional distress and $10,000 for attorneys' fees. The court granted judgment in the amount of $25,000.