Swanson v. Citibank, N.A.
United States Court of Appeals for the Seventh Circuit
614 F.3d 400 (7th Cir. 2010)
Gloria Swanson (plaintiff), who is Black, suspected racial discrimination when a Citibank, N.A. (defendant) representative discouraged her home-equity loan application; after conditionally approving her loan based on her $270,000 home-value estimate, Citibank had Andre Lanier of PCI Appraisal Services (defendants) appraise the home at only $170,000, well below a subsequent independent appraisal of $240,000, leading Citibank to deny the loan. Swanson sued Citibank, Lanier, and PCI under Fair Housing Act § 3605, alleging they worked together to devalue her home as a pretext for denying her a loan because of her race; the district court dismissed her complaint under Rule 12(b)(6) for failure to state a claim.
Whether, under the plausibility standard of Bell Atlantic Corp. v. Twombly, a court's role is to determine whether a set of alleged facts is probable.