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INTERNAL PROTOTYPE — NOT LEGAL ADVICE — DO NOT SEND

Douglas v. Kriegsfeld Corp., 884 A.2d 1109 (2005)

Citation
Douglas v. Kriegsfeld Corp., 884 A.2d 1109 (2005)
Parent Document
Douglas v. Kriegsfeld Corp., 884 A.2d 1109 (2005)
Jurisdiction
DC (municipal)
Effective Date
2005-10-13

Other Sections in This Document (533)

Full Text

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[80] Supra note 22. We have found no basis for Judge Glickman's statement — citing only Jankowski with a cf. signal — that a landlord's failure to open a dialogue with a tenant who requests a reasonable accommodation will not be "material" or "result in liability" (and thus will be excusable) unless the landlord's indifferent behavior not only "operates as a disingenuous excuse for not granting that request" but also "thwarts the development, presentation or evaluation of the tenant's request for a reasonable accommodation." Even if that two-pronged formulation were to state the law correctly, however, we are satisfied that, on this record, a reasonable jury could find the requisite disingenuousness, as well as landlord behavior that thwarted the presentation or evaluation, if not the development, of the tenant's request.