Meyer v. Holley

Background

An interracial couple, Emma Mary Ellen Holley and David Holley, say a Triad, Inc. real estate salesperson refused to sell them a house because of their race. The couple sued the salesman and the corporation, and separately sued David Meyer, who was Triad’s president, sole shareholder, and designated corporate broker. Lower courts dismissed some claims against Meyer, and the Ninth Circuit later held that the Fair Housing Act made owners or officers personally liable simply because they could direct or control an employee.

Reasoning

The Court addressed whether the Fair Housing Act imposed personal, faultless liability on corporate owners or officers for an employee’s discriminatory acts. The Court said the statute itself says nothing about imposing unusual personal liability and that Congress normally legislates against ordinary tort rules. It explained that ordinary agency and employer rules make the corporation, not the individual officer or owner, the usual party responsible for an employee’s misconduct. The Court also relied on Department of Housing and Urban Development guidance that limited liability to acts by employees acting within the scope of their authority. The Ninth Circuit’s broader reading of automatic officer or owner liability was rejected.

Real world impact

As a result, corporations remain the usual defendants in housing discrimination suits for employees’ wrongdoing, while individual officers or owners are not automatically held personally liable without additional legal grounds. The Court vacated the Ninth Circuit’s judgment and sent the case back for further proceedings, including possible questions about state-law agency, license-related duties, or corporate veil-piercing that the appeals court may now address.