Swanson v. Citibank, N.A.

Dist. Ct. erred in dismissing for failure to state cause of action plaintiff's Fair Housing Act claim against defendants-bank and appraisers alleging that defendants intentionally lowered appraisal value of her home in order to deny on account of her race plaintiff's application for home-equity loan. Instant complaint was sufficient to state cause of action where complaint identified type of discrimination, alleged culprits, and time frame of loan application. Fact that complaint alleged other extraneous facts regarding source of loan proceeds or that loan officer had mixed-race family did not serve to plead plaintiff out of her claim. Dist. Ct. did not err, though, in dismissing plaintiff's related fraud claim in absence of allegation that plaintiff relied on defendants' appraisal or that plaintiff incurred monetary loss because of said appraisal.