Nature of the Case
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Facts
D is a landlord. In 2016, Laura Erwin and Mack Teal sought to rent an apartment from D to live in with their six-year-old son (collectively, the Erwin-Teals or the family). Erwin and Teal were not married at the time. D required that they file separate rental applications. Both application forms stated that no children were permitted to reside in the apartment. Erwin and Teal told D they had a son who would be living with them, and d responded that he would allow them to rent on a 'trial basis.' d gave Erwin and Teal a lease that contained a 'no children' clause, but he included a handwritten amendment stating that the 'lease contract is being entered on a trial basis in consideration of the 'no children' clause . . . .' Erwin and Teal signed their lease, which was to expire in one year. Erwin became pregnant with her and Teal's second child. After their lease ended Erwin and Teal continued to rent their apartment month-to-month. D sent Erwin and Teal a letter stating he wanted to renew their lease. Erwin and Teal agreed and signed a renewal contract. Erwin and Teal were relieved to renew the lease, as it gave them 'peace of mind' to know they would have stable housing while caring for a newborn child. Erwin gave birth on May 25, 2017. On June 12, just two weeks after Erwin gave birth, D delivered an eviction letter to Erwin and Teal. The letter demanded that the family vacate the apartment no later than July 31, 2017, because the Erwin-Teals had violated the no children clause in the lease: their son lived in the apartment with them, and Erwin had 'given birth to a girl who is also now living at the apartment.' They implored D for 'a little more time. Teal tried to reason with D that it would be 'inhumane' to put 'a couple out in the street with a newborn baby.' d responded, 'This conversation's not going to happen. You got to go.' They had trouble finding a suitable apartment by the move-out date, so they moved into Erwin's father's house, which was a challenging living situation. Erwin returned to work just five weeks after giving birth-over a month sooner than she had intended. It took six months for Erwin to fully recover from her C-section, which she attributed to the fact that she did not have enough time to rest and heal. P filed suit against Rupp on behalf of the Erwin-Teals under the FHA. The district court granted summary judgment for the government, determining that D violated the FHA by terminating the lease based on familial status; imposing different lease conditions based on their familial status; and using application and lease forms that expressed a preference based on familial status. Erwin was awarded $9,400; Teal was awarded $3,000; and each child was awarded $1,000. For punitive damages, Erwin and Teal were each awarded $10,000, and each child was awarded $20,000. The jury awarded the family $14,400 in compensatory damages and $60,000 in punitive damages. D appealed.
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