Tenant Can't Sue Realtor in Federal Court for Vandalized Apartment Lock

Oneonta tenant sued realtor and its attorney in federal court after his apartment was vandalized in 2024, causing him mental and emotional distress. Tenant claimed that when he moved into the unit in 2023, the apartment door lock was "hanging off" the "paper thin" front door. Although reported to the landlord, the door was never fixed. Tenant asserted his claims against the defendants under 42 USC Section 1983, the federal Fair Housing Act, and state law concerning failure to repair his apartment door. The court ruled against tenant, finding that his claims were insufficient to state a claim under federal or state law. As private parties, the realtor and its attorney were private parties, not "state actors." United Student Rentals didn't own the apartment, and tenant stated no factor connecting the defendant's acts to the conditions involved.

Hartley v. United Student Rentals: Index No. 1:20-CV-928, NYLJ No. 1736175139 (NDNY; 1/3/25; Hummel, MJ)