Human Rights Commission v. LaBrie, Inc.
Vermont Supreme Court
668 A. 2d 659 (Vt. 1995)
LaBrie (defendant) operated a trailer park that originally barred residents with minor children outright; after Vermont law changed to prohibit that kind of discrimination, LaBrie adopted a facially neutral policy limiting each home to two occupants, though no families with minor children moved in even after the change. When the McCarthys, existing residents, had a child and returned from the hospital to a notice to vacate "upon arrival of your third occupant," they complained to the Human Rights Commission (plaintiff), which sued LaBrie for unlawfully discriminating based on the presence of a minor child; the trial court ruled for the Commission, and LaBrie appealed.
Whether a privately enforced per dwelling limit of two occupants is reasonable.