Short v. Manhattan Apts., Inc

In Short v. Manhattan Apts., Inc. (916 F Supp 2d 375 [SD NY 2012]), the federal court held that the "source of income" provision was violated when real estate brokers refused to rent apartments to a prospective tenant who sought to pay his rent with a rental assistance subsidy from the New York City HIV/AIDS Services Administration ("HASA"). The court explicitly acknowledged that NYCHRL's source-of-income provision should be "construed 'liberally for the accomplishment of its uniquely broad and remedial purposes,' N.Y. City Admin. Code 8-130, as it clearly favors Plaintiffs' interpretation" that the defendants' failure to accept HASA rental assistance benefits violated section 8-107 (5) (a) (1) of the Administrative Code.