Havens Realty Corp. v. Coleman
United States Supreme Court
455 U.S. 363 (1982)
Havens Realty Corporation (defendant) owned apartment complexes and told Sylvia Coleman, who was Black, that no apartments were available while telling Kent Willis, who was white, that vacancies existed — both were employed by a fair-housing organization to test Havens's rental practices, without any actual intent to rent. Coleman, Willis, and their organization sued under the Fair Housing Act, and the district court found they lacked standing because, as testers, they never truly intended to live in a Havens apartment; the Fourth Circuit reversed.
Whether the actual or threatened injury required for Article III standing can exist solely by virtue of a statute that creates a legal right, even for a plaintiff who never intended to use the right for its ordinary purpose.