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    SAMARITAN INNS INC v DC
    United States Court of Appeals

    FOR THE DISTRICT OF COLUMBIA CIRCUIT

    Argued March 31, 1997 Decided June 6, 1997

    No. 96-7105

    Samaritan Inns, Inc.,

    Appellee/Cross-Appellant

    v.

    District of Columbia, et al.,

    Appellants/Cross-Appellees

    Consolidated with

    Nos. 96-7106 and 96-7109

    Appeals from the United States District Court

    for the District of Columbia

    (No. 93cv02600)

    Lutz Alexander Prager, Assistant Deputy Corporation

    Counsel, argued the cause for appellants/cross-appellees, with


    whom Charles F.C. Ruff, Corporation Counsel, and Charles L.

    Reischel, Deputy Corporation Counsel, were on the briefs.

    John R. Risher Jr., argued the cause for appellee/cross-

    appellant, with whom James P. Mercurio was on the briefs.

    Before: Wald, Rogers and Tatel, Circuit Judges.

    Opinion for the Court filed by Circuit Judge Rogers.

    Rogers, Circuit Judge : The District of Columbia and two

    of its employees, Hampton Cross and Patricia A. Montgomery

    (collectively "the District") appeal a judgment awarding ap-

    proximately $2.4 million in compensatory damages, $1,000 in

    punitive damages, and $684,624 in attorney's fees and costs to

    Samaritan Inns, Inc., for violations of the Fair Housing Act,

    42 U.S.C. §§ 3601-3631. The District does not contest the

    district court's finding that it violated the Act by issuing an

    illegal stop-work order that temporarily prevented Samaritan

    Inns from completing renovations to a residential housing

    facility for former drug and alcohol abusers, and by initiating

    proceedings to revoke the facility's construction permits.

    Rather, the District contends that the record does not sup-

    port the district court's award of compensatory damages for

    "lost" and "delayed" charitable contributions to Samaritan

    Inns, approximately $2.3 million, or the award of punitive

    damages against Cross and Montgomery. Samaritan Inns

    cross-appeals the district court's denial of relief on its claim

    that the District violated the Fair Housing Act by failing to

    make reasonable accommodations in its zoning laws.

    We hold that because Samaritan Inns did not establish with

    reasonable certainty that the District's actions caused any

    potential contributors to refrain from making donations to its

    capital campaign, it is not entitled to recover damages for

    "lost" contributions. We further hold that Samaritan Inns

    may recover damages for "delayed" capital contributions, but

    that the district court's findings as to the duration of the

    delay are clearly erroneous. We affirm the award of punitive

    damages against Cross and Montgomery. Accordingly, we

    reverse the awards of compensatory damages for "lost" and

    "delayed" capital contributions, and we remand the case for


    recalculation of the award for "delayed" contributions and for

    reconsideration of the attorney's fees award.

    I.

    Samaritan Inns is a tax-exempt charitable corporation that

    provides below-market rental housing to former drug and

    alcohol abusers in the District of Columbia. It operates three

    "Inns" that provide short-term transitional housing, and two

    "Houses"_Lazarus House and Tabitha's House_that pro-

    vide longer-term housing. As a condition of living in either

    the Inns or the Houses, all tenants must have completed an

    approved substance abuse program, must obtain and maintain

    gainful employment, and must refrain from using drugs and

    alcohol.

    A.

    Background to the litigation . Lazarus House opened in

    1991. Within two years, it received nearly 800 applications

    from men and women who met the criteria for living there.

    Because it was unable to meet this demand, Samaritan Inns

    decided to open a second House modeled after Lazarus House

    and, in 1992, purchased the building now known as Tabitha's

    House. In 1993, the District issued the demolition and

    building permits necessary to allow Samaritan Inns to reno-

    vate Tabitha's House and operate it as a boarding house. 1  

    Shortly after work on the project began, however, residents

    of the surrounding community began to express opposition to

    the housing facility. On September 22, 1993, David Erickson,

    the president of Samaritan Inns, met with community resi-

    dents to discuss the Tabitha's House project. Also attending

    the meeting were appellant Cross, then the Acting Director of

    the D.C. Department of Consumer and Regulatory Affairs;

    Joseph Bottner, the D.C. Zoning Administrator; and the

    Honorable Charlene Drew Jarvis, D.C. Council Member for


    Ward 4, in which Tabitha's House is located. At the meeting,

    community residents argued that Tabitha's House could not

    be considered a boarding house under the zoning laws be-

    cause it would not serve meals, and demanded that Cross

    issue an order stopping all work on the project.

    Erickson subsequently met with the Zoning Administrator

    and community residents in an effort to resolve issues relat-

    ing to the Tabitha's House meal plan. Opponents of the

    project, including the Ward 4 Council Member, continued to

    press for a stop-work order. On October 7, 1993, the Zoning

    Administrator issued an order requiring Samaritan Inns to

    stop all construction work on Tabitha's House. The order

    contained no discernible explanation of why it had been

    issued. Although the Zoning Administrator shortly thereaf-

    ter recommended to Cross that the order be vacated, Cross

    refused to rescind it, claiming that the Mayor had decided to

    support the protesters. On October 18, 1993, appellant Mont-

    gomery, the Acting Director of the D.C. Building and Land

    Regulation Administration in the Department of Consumer

    and Regulatory Affairs, sent Erickson a letter purporting to

    revoke the building and demolition permits for Tabitha's

    House on the ground that Samaritan Inns had misrepresen-

    ted to the District that the building would be used as a

    boarding house.

    The District later acknowledged that the October 18 revo-

    cation order was invalid because Samaritan Inns had not

    received a hearing. On November 19, 1993, Montgomery

    issued a Notice of Intent to Revoke Permit, reiterating the

    charge that Samaritan Inns had falsely represented in its

    permit applications that it intended to operate the Tabitha's

    House property as a "boarding house." The notice also

    charged that Lazarus House, the model for Tabitha's House,

    was being operated as a "community-based residential facili-

    ty," rather than a boarding house. 2 At Cross's direction, a


    citation charging that Lazarus House had violated its certifi-

    cate of occupancy was also issued, but not served. Samari-

    tan Inns requested an expedited hearing, and on December

    28, 1993, an administrative law judge found that the District

    had not proven any false statements in the permit applica-

    tions for Tabitha's House. The judge also found that there

    was no evidence that Lazarus House was being operated as a

    community-based residential facility or that Samaritan Inns

    intended to provide counseling or residential services at Ta-

    bitha's House that would make it a community-based resi-

    dential facility under the zoning laws. The judge further

    found that even if Samaritan Inns did not intend to provide

    meals, Tabitha's House would still qualify as a "rooming

    house," rather than a "boarding house." 3 Under the zoning

    regulations, both boarding houses and rooming houses are

    uses that are permitted as of right in the area where Tabi-

    tha's House is located, an R-5 residential zone. D.C. Mun.

    Regs. tit. 11, §§ 330.6, 350.4(a) (1995). If Tabitha's House

    had been classified as a community-based residential facility,

    the number of occupants permitted in the facility would have

    been limited, and Samaritan Inns would have been required

    to obtain permission from the Board of Zoning Adjustment

    ("BZA") to operate the facility. 4  

    During the course of this controversy, the stop-work order

    remained in effect. On December 20, 1993, Samaritan Inns

    filed the instant lawsuit alleging violations of District of

    Columbia law, the Civil Rights Act of 1871, the Fair Housing


    Act, and the Due Process Clause of the Fifth Amendment.

    On January 12, 1994, the District rescinded the stop-work

    order, and on March 15, 1994, the parties entered into a

    consent order, pursuant to which the District agreed not to:

    revoke or seek to revoke plaintiff's building permits

    relating to Tabitha's House, nor issue a stop-work order

    pertaining to work being done on Tabitha's House pursu-

    ant to those permits, except as may be necessary either

    to protect the public from a dangerous physical condition

    arising at Tabitha's House or on the basis of information

    not of record which would warrant revocation or a stop-

    work order under the law....

    Despite this agreement, Cross subsequently caused the cita-

    tion against Lazarus House to be served on March 21, 1994.

    The District canceled that citation on April 6, 1994.

    The construction and renovation of Tabitha's House was

    completed in June 1994. In July, the Zoning Administrator

    issued a certificate of occupancy for its use as a rooming and

    boarding house. Opposition from the surrounding community

    continued, and residents appealed the issuance of the certifi-

    cate of occupancy to the BZA. In September 1996, the BZA

    denied the appeal.

    After a bench trial in February 1995, the district court

    entered judgment for Samaritan Inns on most of its Fair

    Housing Act claims. The district court found that the ten-

    ants of Tabitha's House and Lazarus House were persons

    with a "handicap" under § 802(h) of the Act, 42 U.S.C.

    § 3602(h), 5 and that the District's actions were motivated by


    discriminatory intent, had a discriminatory effect, and

    "coerced or intimidated" Samaritan Inns from continuing its

    efforts to complete and open Tabitha's House, in violation of

    §§ 804 and 818 of the Act, 42 U.S.C. §§ 3604, 3617. 6 The

    district court found, however, that Samaritan Inns had failed

    to present persuasive evidence that the District had violated

    the "reasonable accommodations" provision of the Fair Hous-

    ing Act. 7 In light of its disposition, the court declined to

    address Samaritan's Due Process claim. The court also

    concluded that neither Cross nor Montgomery was entitled to

    qualified immunity. The court awarded Samaritan Inns


    $2,404,903 in compensatory damages, and assessed punitive

    damages of $500 each against Cross and Montgomery. It

    also awarded Samaritan Inns attorney's fees and costs of

    $684,624.83, and ordered the District to cease and desist its

    discriminatory practices.

    B.

    The damages award. More than $2.3 million of the com-

    pensatory damages award was intended to compensate Sa-

    maritan Inns for harm to a planned capital fundraising cam-

    paign, the "Next Steps Initiative." When the Tabitha's

    House controversy began, Samaritan Inns was planning to

    solicit $8 million in donations to finance the cost of construct-

    ing five new Inns providing short-term housing, two new

    Houses similar to Lazarus House and Tabitha's House, and a

    support center, and to create a $2 million endowment fund to

    help support the operating costs of the residences. Once the

    controversy began, however, Samaritan Inns decided not to

    commence this campaign in 1994, as originally planned. The

    district court found that "the devastating impact of the [Dis-

    trict's] actions, commencing with the issuance of the stop-

    work order on October 7, 1993," effectively prevented Samari-

    tan Inns from achieving its fundraising goals because it

    "chilled the interest in potential donors and previously active

    Samaritan Inns board members in donating to and working

    with [Samaritan Inns] until the cloud of controversy and

    delay lifted."

    The evidence to support the district court's conclusion came

    primarily from Erickson and John Derrick, the president of

    Potomac Electric Power Company ("PEPCO"), who was

    chairman of the Tabitha's House fundraising board. Erick-

    son testified that once the stop-work order was issued, the

    conflict concerning Tabitha's House became "almost the sole

    focus" of his meetings with the fundraising board, and the

    board members began to evidence a lack of interest in

    continuing to work with Samaritan Inns. Derrick testified

    that the stop-work order "basically just knocked the pins

    right out from underneath of us." In Derrick's view, the


    District's actions, including those of the Ward 4 Council

    Member, raised serious doubts as to whether Samaritan Inns

    would be able to continue to operate in the District of

    Columbia, and made it impossible to go forward with the

    Next Steps Initiative. In the wake of the stop-work order,

    the board was unable to raise approximately $196,000 needed

    to complete the Tabitha's House campaign. 8 However, Erick-

    son and his staff were nonetheless able to raise most of the

    funds necessary to close this shortfall.

    To calculate the dollar impact of the District's actions on

    the Next Steps Initiative, Erickson assumed that some por-

    tion of the potential contributions that he would have solicited

    had been irretrievably "lost" and that the remainder had

    merely been "delayed." He calculated the total amount lost

    during 1994 and 1995 at $1,958,501. The district court ac-

    cepted these figures, and found them to be consistent with

    the analysis of Samaritan Inns' economic expert, Dr. Richard

    Edelman. Edelman used the past pattern of contributions to

    Tabitha's House and three indexes of business and economic

    activity to estimate the amount that Samaritan could have

    expected to receive from October 1993 to October 1994. He

    then calculated the amount of "lost" contributions as the

    difference between this expected level of contributions and

    the amount of contributions that Tabitha's House actually

    received during the same period. Using this methodology,

    Edelman estimated the total loss as between $2.05 million and

    $2.88 million.

    Edelman further calculated that a delay of two years would

    reduce the value to Samaritan Inns of the funds Erickson had

    classified as "delayed" by $385,723. Edelman also calculated

    the loss in value of the funds that Erickson testified he had

    expected to receive for the completion of the Tabitha's House

    campaign from November 1993 to January 1994, concluding


    that a delay in receipt until June 1994 reduced their value to

    Samaritan Inns by $3,442.

    The remaining testimony on the issue of damages to Sa-

    maritan Inns' fundraising prospects came from Dr. James

    Gelatt, a fundraising expert retained by the District. Gelatt

    and two other experts, one of whom was retained by Samari-

    tan Inns and the other by the District, formed a panel that

    interviewed twenty-one past or potential donors to Samaritan

    Inns, selecting the interviewees from a list that Samaritan

    Inns had provided. The expert panel concluded that Samari-

    tan Inns "continues to enjoy a positive reputation among

    those individuals, corporations, foundations, church groups,

    and other organizations from whom it has and would be

    anticipated in the future to solicit capital contributions."

    Gelatt testified that prior to the Tabitha's House controversy,

    Samaritan Inns had the capacity to meet the goals of the

    Next Steps Initiative, and that the expert panel had conclud-

    ed that it would still be able to meet those goals "if it receives

    support in its efforts from the D.C. government and if the

    volunteer leadership is still 'on board.' " Gelatt also testified

    that while the members of the panel "felt that we could

    comfortably say that there was some impact" on Samaritan

    Inns' fundraising capability as a result of the controversy,

    "none of us ... felt that we could quantify it." The expert

    panel was unable to conclude "whether the impact [was] an

    outright loss of contributions, or merely a delay in their

    receipt (based at least in part on Samaritan Inns' election not

    to proceed with the Next Steps Initiative)."

    The district court found that the earliest prudent date for

    Samaritan Inns to begin the Next Steps Initiative was Janu-

    ary 1996, and it accepted Erickson's estimates of "lost" and

    "delayed" contributions and Edelman's calculations of the

    diminution in value caused by the delay. The court therefore

    awarded Samaritan Inns $1,958,500 for "lost" contributions,

    $385,723 for the reduction in value of "delayed" donations to

    the Next Steps Initiative, and $3,440 for the reduction in

    value of the delayed donations to the Tabitha's House cam-

    paign. The district court also awarded $57,240 to compensate

    Samaritan Inns for construction delay and staff overhead,


    bringing the total award of compensatory damages to

    $2,404,903.

    II.

    Section 813(c) of the Fair Housing Act, 42 U.S.C. § 3613(c),

    provides that "if the court finds that a discriminatory housing

    practice has occurred or is about to occur, the court may

    award to the plaintiff actual and punitive damages...." On

    its face, nothing in this language suggests any limit on the

    type of "actual damages" that a plaintiff may recover. Nor

    does the legislative history of the Act suggest any such

    limitation. 9 However, the parties have not cited a case, nor

    are we aware of one, in which a plaintiff has sought to recover

    damages under the Fair Housing Act for a defendant's inter-

    ference with a fundraising campaign. Nonetheless, although

    the District contends that Samaritan Inns' claims of injury

    are unduly speculative and remote, it does not contend that

    such damages are not recoverable under § 813(c), upon a

    proper showing of causation.

    Furthermore, we recognize that the language of the Act is

    "broad and inclusive" and must be given a "generous con-

    struction." Trafficante, 409 U.S. 205, 209 , 212 (1972); see


    also City of Edmond v. Oxford House, Inc., 115 S. Ct. 1776,

    1780 (1995). The Supreme Court has recognized that an

    action for damages under § 813 may be analogous to several

    different tort actions recognized at common law, including

    actions for defamation or intentional infliction of emotional

    distress. Curtis v. Loether, 415 U.S. 189, 195 & n.10 (1974).

    Whatever the appropriate analogy, "[a] damages action under

    the statute sounds basically in tort_the statute merely de-

    fines a new legal duty, and authorizes the courts to compen-

    sate a plaintiff for the injury caused by the defendant's

    wrongful breach." Id. at 195.

    It cannot be gainsaid that just as the success of a for-profit

    business may depend on the good will of its customers, see,

    e.g., Newark Morning Ledger Co, v. United States, 507 U.S.

    546, 555-56 (1993), many charitable enterprises such as Sa-

    maritan Inns depend largely on donations from the public for

    their continued success. See, e.g., Henry B. Hansmann, The

    Role of Nonprofit Enterprise, 89 Yale L.J. 835, 840-41 (1980).

    Furthermore, because such enterprises cannot sell equity

    shares, they often depend heavily on outside contributions for

    capital financing. Id. at 877. By issuing a stop-work order

    because Samaritan Inns had purportedly misrepresented its

    intentions in its permit applications, and by otherwise ob-

    structing the completion of Tabitha's House, the District

    could reasonably have foreseen that its actions might, at least

    temporarily, adversely affect Samaritan Inns' image as an

    efficient and reputable provider of charitable services, and

    thereby impair its ability to raise funds. 10   Cf. Restatement

    (Second) of Torts § 561(b) (1977); 2 Fowler V. Harper et al.,

    The Law of Torts § 5.3 (2d ed. 1986). In related contexts,

    the court has recognized that for-profit corporations may


    recover lost or delayed profits. For example, in ALPO

    Petfoods, Inc. v. Ralston Purina, Inc., 997 F.2d 949 (D.C. Cir.

    1993), a competitor's false advertising campaign forced a dog

    food manufacturer to delay introduction of a new product into

    the national market, and the court upheld an award of

    damages under § 43(a) of the Lanham Act, 15 U.S.C.

    § 1125(a) for the delay in receipt of profits. See also Art

    Metal-U.S.A., Inc. v. United States, 753 F.2d 1151, 1156

    (D.C. Cir. 1985). We see no principled basis on which to

    conclude that a nonprofit corporation, such as Samaritan

    Inns, may not recover contributions lost or delayed as a

    result of the District's unlawful interference with its activities

    if such interference was the proximate cause of the loss. See

    Harper et al., supra, § 5.3.

    To determine whether Samaritan Inns has met this burden

    of proof to show loss and causation, we apply settled princi-

    ples governing the recovery of damages for lost profits. Both

    parties agree that the relevant standards are stated in Story

    Parchment Co. v. Paterson Parchment Paper Co., 282 U.S.

    555, 563 (1931):

    Where the tort itself is of such a nature as to preclude

    the ascertainment of the amount of damages with cer-

    tainty, it would be a perversion of fundamental principles

    of justice to deny all relief to the injured person, and

    thereby relieve the wrongdoer from making any amend

    for his acts. In such case, while the damages may not be

    determined by mere speculation or guess, it will be

    enough if the evidence show the extent of the damages as

    a matter of just and reasonable inference, although the

    result be only approximate.

    Id. at 563. Thus, while a plaintiff seeking to recover lost

    profits must ordinarily prove the fact of injury with reason-

    able certainty, proof of the amount of damages may be based

    on a reasonable estimate. Office & Professional Employees

    Intern. Union, Local 2 v. FDIC, 27 F.3d 598, 602 (D.C. Cir.

    1994); Eureka Investment Corp., N.V. v. Chicago Title Ins.

    Co., 743 F.2d 932, 938 (D.C. Cir. 1984); Restatement, supra,

    § 912 & cmt. d; 1 Robert L. Dunn, Recovery of Damages for

    Lost Profits § 1.3, at 11 (4th ed. 1992). Although a court will


    not permit a plaintiff to recover damages based on "mere

    speculation or guess," see Wood v. Day, 859 F.2d 1490, 1493

    (D.C. Cir. 1988), the fact that an estimate is uncertain or

    inexact will not defeat recovery, once the fact of injury is

    shown. Dunn, supra, at 11.

    Applying this framework to the District's contention that

    the record does not support the district court's award of more

    than $2.3 million to compensate Samaritan Inns for "lost" and

    "delayed" contributions to the Next Steps Initiative, we con-

    clude that Samaritan Inns is not entitled to recover damages

    for "lost" contributions because it has not shown with reason-

    able certainty that any contributions were lost. The primary

    evidence concerning lost contributions came from Erickson,

    whose testimony did not provide any clear explanation as to

    why some of the funds Samaritan Inns expected to receive in

    1994 and 1995 were irretrievably "lost," while the remaining

    amounts were merely "delayed." Erickson testified that he

    and his staff expected to solicit $4 million from ten potential

    donors in the first phase of the Next Steps campaign in 1994.

    Based on past giving patterns, he anticipated that 85% of that

    sum would be paid over a three-year period, and that the

    remaining 15%, or $600,000, would be paid in a lump sum

    during 1994. In his damages estimate, Erickson assumed

    that this $600,000 in lump-sum contributions had been "lost,"

    but that the contributions expected to be paid over the three-

    year period had merely been delayed. Similarly, Erickson

    testified that in the second phase of the campaign, he planned

    to raise $650,000 from individual and corporate contributors,

    and that a fundraising board similar to those used in the

    Lazarus House and Tabitha's House campaigns was expected

    to raise $650,000. Again, he assumed that 85% of this sum

    would be paid over three years, and that the remaining 15%,

    or a total of $195,000, would be paid in a lump sum in 1994.

    Erickson also classified this $195,000 lump sum payment as

    "lost." In 1995, in the third phase of the campaign, Erickson

    planned to raise $300,000 from individual and corporate con-

    tributors, and expected the fundraising board to raise

    $850,000. Relying on historical patterns, Erickson assumed

    that 51% of the later donations would be paid on a multi-year


    basis. He classified the remaining 49%, or $563,000, as "lost"

    lump sum contributions.

    Although he offered no testimony on this point, a four-page

    analysis prepared by Erickson indicated that he also planned

    to solicit $700,000 from foundations in 1994 and $850,000 in

    1995. The analysis indicates that he expected approximately

    one-third of the foundation grants to have been "lost" rather

    than delayed. Erickson classified $250,000 of the foundation

    grants from 1994 and $200,000 of the grants from 1995 as

    "lost." Thus, Erickson concluded that $1,045,000 of the

    $2,996,667 Samaritan Inns expected to receive in 1994 and

    $913,500 of the $3,110,667 it had expected to receive in 1995

    had been "lost."

    Erickson's calculations regarding the "lost" contributions

    depended upon the premise, accepted by the district court,

    that fundraising is cyclical, and that in any given year contrib-

    utors have a finite amount of money to donate to worthy

    causes. Thus, if circumstances prevented Samaritan Inns

    from soliciting money in a particular year, it would have

    irretrievably lost the opportunity to compete for the funds

    that were distributed in that year. Although it could conceiv-

    ably raise the same amount of money in a different year,

    those contributions would come out of a different pool of

    funds. As Erickson explained, "[t]he people that have the

    capacity to give this kind of money give this generously ...

    on a regular basis. That money that wasn't given in 1994 was

    given for something else. And so that money is not available

    to Samaritan Inns." This type of analysis is, in some re-

    spects, analogous to the manner in which contract law treats

    "lost-volume" sellers. If, for example, a buyer breaches a

    contract to purchase a car from an automobile dealer, the fact

    that the dealer is subsequently able to resell the car to a

    second buyer at the same price does not mean that the dealer

    has suffered no damage. Had it not been for the first buyer's

    breach, the dealer would have sold two cars, and earned

    profit on both. Hence, the dealer is entitled to recover the

    lost profit on the sale of one car. See U.C.C. § 2-708(2);

    Neri v. Retail Marine Corp., 30 N.Y.2d 393 (1972). Similarly,

    if a charity solicits money on an annual basis, a donation in


    one year will not compensate the charity for a donation "lost"

    in a prior year as a result of a defendant's misconduct. Had

    it not been for the misconduct, the charity would have re-

    ceived contributions in both years.

    The problem with the "lost" contributions analysis is that

    the Next Steps Initiative, as Erickson explained it to the

    district court, was not an annual giving program. Rather, it

    was a capital fundraising drive of limited duration intended to

    raise a specified sum of money for the construction of new

    Houses and Inns and the creation of an endowment. Erick-

    son acknowledged that "[c]apital projects are, by definition,

    special projects," and distinguished between the sums that

    Samaritan Inns raised for capital projects and the funds it

    raised to defray its operating costs. There is nothing in the

    record to suggest that Samaritan Inns would have continued

    to solicit capital contributions indefinitely once it received the

    $8 million it hoped to raise in 1994 and 1995. To the

    contrary, Erickson described the campaign as a three-year

    endeavor. Thus, there was no basis for the district court to

    conclude that Samaritan Inns had irretrievably lost any funds

    merely because it lost the opportunity to compete for the

    funds available in 1994 and 1995. Given the limited duration

    of the capital campaign, Samaritan Inns could mitigate that

    loss by raising the amount that it planned to raise in 1996 and

    subsequent years. Assuming that it could raise the same

    amount at a later time, its damages would be limited to any

    injury caused by the delay.

    Had the Next Steps Initiative been an annual giving cam-

    paign, rather than a capital campaign of limited duration,

    Edelman's analysis might well have provided a relevant mea-

    sure of damages. As noted, Edelman estimated the amount

    of contributions that the Next Steps Initiative could have

    expected to receive between October 1993 and October 1994,

    relying on historical patterns of contributions to the Tabitha's

    House campaign and various indexes of business activity.

    His analysis indicated that Tabitha's House could have ex-

    pected to receive between $2.05 and $2.8 million during that

    one-year period. If the Next Steps Initiative were an annual

    event expected to continue for the indefinite future, Edelman


    might have reasonably concluded that Samaritan Inns had

    irretrievably lost this sum of money. But neither Edelman's

    analysis nor any other evidence offered by Samaritan Inns

    explained why, under the circumstances, Samaritan Inns

    could not simply make up the "lost" contributions in later

    years and still achieve the goals of the campaign.

    Furthermore, contrary to the district court's finding, Edel-

    man's analysis did not "fully support" Erickson's damages

    estimates. Although both concluded that Samaritan Inns had

    suffered damages in the $2 million range, their calculations

    measured different things. Erickson assumed that the

    "lump-sum" contributions and a portion of the foundation

    grants that Samaritan Inns had expected to receive in 1994

    and 1995 had been "lost," but that the remaining funds that

    Samaritan Inns had expected to receive had merely been

    delayed. If, as Erickson contended, the delay meant that

    Samaritan Inns had forever lost the opportunity to compete

    for those funds available in 1994 and 1995, it is unclear why

    the remaining contributions were not also "lost," rather than

    delayed. Edelman, by contrast, conducted an analysis appro-

    priate for an annual campaign, assuming that Samaritan Inns

    had "lost" the entire difference between the contributions it

    could have received in the wake of the Tabitha's House

    controversy and the contributions it actually received. Not

    only did he employ a different methodology, but he examined

    a different period of time. Erickson's calculations covered

    the two-year period from 1994 to 1995, while Edelman's

    covered the one-year period from October 1993 to October

    1994. Given these significant differences in methodology, the

    fact that Edelman and Erickson reached similar estimates of

    Samaritan Inns' damages was mere coincidence.

    This is not to suggest that a charitable organization could

    never recover damages for lost contributions to a limited-

    duration capital fundraising campaign. Samaritan Inns could

    have demonstrated permanent losses by presenting evidence

    that particular contributors who might otherwise have made

    contributions in 1994 and 1995 were unwilling to do so in the

    wake of the Tabitha's House controversy, and that Samaritan

    Inns was unable to secure contributions from alternative


    sources. It did not present any evidence to this effect,

    although Erickson did testify that he felt the members of the

    Tabitha's House fundraising board would be reluctant to be

    involved in the Next Steps Initiative. 11 The best evidence of

    the reactions of potential contributors to the Tabitha's House

    controversy came from the interviews conducted by the panel

    of fundraising experts. The comments that Gelatt, a member

    of the expert panel, cited in his written declaration did reflect

    some hesitation on the part of contributors to give money to

    Samaritan Inns until it resolved its problems with the Dis-

    trict, but none of the cited comments suggest that any

    contributor viewed these problems as an absolute barrier to

    future contributions. Furthermore, Gelatt testified that al-

    though the expert panel members thought that the District's

    actions had some impact on Samaritan Inn's fundraising

    capability, they were unable to quantify it or to state with any

    certainty whether the impact would be manifested as an

    outright loss or merely as a delay. Given the dearth of

    evidence and the conflicting methodologies used by Erickson

    and Edelman, we conclude that Samaritan Inns did not prove

    with reasonable certainty that it had lost any capital contribu-

    tions. Consequently, the district court's finding that Samari-

    tan Inns lost $1,958,501 in 1994 and 1995 was clearly errone-

    ous.

    The district court's award of damages for the delayed

    receipt of the Next Steps Initiative funds is a different

    matter. Through the testimony of Erickson and Derrick,

    Samaritan Inns presented substantial evidence to support the

    district court's finding that the District's actions forced a

    delay in the commencement of the Next Steps Initiative.

    Having demonstrated the fact of a delay with reasonable

    certainty, Samaritan Inns was only required to prove the

    extent of its damages "as a matter of just and reasonable


    inference, although the result be only approximate." Story

    Parchment, 282 U.S. at 563 . While neither Erickson nor the

    district court could know with certainty whether Samaritan

    Inns ultimately would meet the goals of the Next Steps

    Initiative, Gelatt testified that those goals were reasonable

    and attainable. Given this expert testimony, the district

    court could reasonably rely on Erickson's estimates of the

    amount Samaritan expected to raise through the Next Steps

    Initiative as more than "mere speculation and conjecture."

    Id.; cf. Wood, 859 F.2d at 1493.

    Samaritan Inns is, however, only entitled to recover dam-

    ages for delays caused by the District, not for delays caused

    by factors over which the District had no control, such as

    community opposition to Tabitha's House. The district court

    concluded that as a result of the District's actions, Samaritan

    Inns was unable to raise any capital contributions from

    October 1993, when the stop-work order was issued, to the

    time of trial in February 1995, and that the "earliest prudent

    commencement date for the Next Steps Initiative [was] 1996."

    Therefore, it awarded Samaritan Inns damages for a delay of

    two years. The district court's finding that the District's

    actions forced a two-year delay in the receipt of funds by

    Samaritan Inns is clearly erroneous. At the very latest, the

    District had ceased to oppose Samaritan Inns' activities by

    July 12, 1994, when it issued a certificate of occupancy for

    Tabitha's House. As early as March 15, 1994, the District

    had entered into a consent agreement not to revoke the

    Tabitha's House permits or attempt to stop work on the

    project without a legitimate reason. Although Cross caused a

    citation to be issued against Lazarus House after the consent

    order was issued, that matter was quickly resolved. After

    the issuance of the certificate of occupancy for Tabitha's

    House, Samaritan Inns' fundraising efforts were still presum-

    ably hindered by significant obstacles unrelated to the Dis-

    trict, including most notably, the appeal to the BZA in August

    1994 by community residents seeking to revoke Tabitha

    House's certificate of occupancy. But the District cannot be


    held responsible for that delay. 12 Furthermore, Samaritan

    Inns is entitled to recover only for the delay that could not

    reasonably have been minimized had Samaritan Inns begun

    its capital campaign once the consent decree was entered.

    Under these circumstances, the maximum period of delay

    reasonably attributable to the District's actions is nine

    months, from the time the stop-work order was issued in

    October 1993 to the time the certificate of occupancy was

    issued in July 1994. The minimum period of delay is three

    months, from the issuance until the revocation of the stop-

    work order. Therefore, we remand the case to the district

    court for redetermination of the period of delay reasonably

    attributable to the District, and recalculation of the amount of

    Samaritan Inns' damages. 13 On remand, because Samaritan

    Inns did not demonstrate any "lost" contributions, the entire

    sum of $8 million that it expected to receive from 1994 to 1997

    must be classified as "delayed." 14  


    III.

    The remaining issues do not require extensive discussion.

    First, the District contends that Cross and Montgomery were

    entitled to qualified immunity because they could reasonably

    have believed that their actions were lawful. Additionally, it

    contends that the district court abused its discretion in

    awarding punitive damages against Cross and Montgomery

    for their "reckless and callous indifference" to Samaritan

    Inns' rights under the Fair Housing Act. The District focus-

    es on a 1992 decision by the BZA ruling that a building that

    provided former prison inmates with housing, as well as

    religious guidance and assistance with financial matters, had

    to be classified under the zoning laws as a community-based

    residential facility, rather than as a rooming or boarding

    house. The District maintains that, based on this precedent,

    Cross and Montgomery could reasonably have believed that

    Tabitha's House was a community-based residential facility.

    Government officials who violate a plaintiff's civil rights are

    entitled to qualified immunity if the officials reasonably could

    have believed that their actions were lawful in light of clearly

    established federal law and the information available to them

    at the time the actions took place. Anderson v. Creighton,

    483 U.S. 635, 641 (1987). Punitive damages for violations of

    federal law are available where a defendant's conduct is

    "motivated by evil motive or intent, or when it involves

    reckless or callous indifference to the federally protected

    rights of others." Smith v. Wade, 461 U.S. 30, 56 (1982).

    The district court found that Cross and Montgomery were not

    entitled to qualified immunity, and that punitive damages

    were appropriate, based on their entire course of conduct

    during the Tabitha's House controversy. For example, the

    district court found that the October 1993 stop-work order

    was facially invalid because it contained no explanation of why

    it had been issued. Although the Zoning Administrator

    recommended that the order be vacated, Cross refused to do

    so, claiming that the Mayor had decided to support the

    protesters. As a result, the stop-work order remained in

    effect until mid-January 1994. Cross also directed Montgom-

    ery to revoke the building and demolition permits for Tabi-


    tha's House. Montgomery then wrote a letter purporting to

    revoke the permits without the hearing required under Dis-

    trict law. Even if Cross and Montgomery could reasonably

    have believed that Tabitha's House was a community-based

    residential facility by reason of the BZA's 1992 decision, there

    is nothing in the record to suggest that they could have

    reasonably believed that these actions were lawful. To the

    contrary, the district court found that these actions were

    motivated by intentional discrimination against the prospec-

    tive residents of Tabitha's House on the basis of their handi-

    caps. Given the course-of-conduct evidence, the district

    court's findings that Cross and Montgomery were not entitled

    to qualified immunity and that they acted with reckless and

    callous disregard for Samaritan Inns' rights are not clearly

    erroneous. Hence, the district court did not abuse its discre-

    tion in awarding punitive damages.

    Second, the District contends that if it prevails in this court

    as to the compensatory damages award for "lost" and "de-

    layed" contributions to the Next Steps Initiative, the case

    should also be remanded for reconsideration of the award of

    attorney's fees and costs. We agree. Samaritan Inns con-

    fined its response to this contention by asserting, in a foot-

    note to its brief, that there was nothing in the record to

    indicate that the fee award was related to the lost contribu-

    tions award. As a prevailing plaintiff, Samaritan Inns is

    entitled to recover reasonable attorney's fees and costs be-

    cause the District has not demonstrated any circumstances

    that would make such an award unjust. 42 U.S.C.

    § 3613(c)(2); Hensley v. Eckerhart, 461 U.S. 424, 429 (1983).

    The reasonableness of the award, however, may turn on the

    degree of success that a plaintiff achieves. Id. at 434-36. On

    remand, therefore, the district court shall reconsider the

    award, determining whether to reduce it in light of the

    revised level of success that Samaritan Inns ultimately

    achieves.

    Finally, Samaritan Inns cross-appeals the district court's

    denial of its "reasonable accommodation" claim under 42

    U.S.C. § 3604(f)(3)(B). This claim stems from a letter of

    December 1, 1993, that counsel for Samaritan Inns wrote to


    Cross. The letter requested that the District agree that the

    social services that Samaritan Inns planned to provide at

    Tabitha's House were permitted as a matter of right, and

    agree to issue a certificate of occupancy for Tabitha's House

    as a boarding, rooming, or apartment house once construction

    was completed. In the complaint, Samaritan Inns alleged

    that the District violated § 3604(f)(3)(B) by failing to agree to

    these proposals. The district court addressed this issue in

    cursory fashion, noting only that "Samaritan Inns has failed

    to present persuasive evidence in support of this claim."

    The District properly points out that we need not address

    Samaritan Inns' "reasonable accommodation" contentions be-

    cause they are moot. The District has issued a certificate of

    occupancy for Tabitha's House as a rooming and boarding

    house. Thus, the District has made it clear that the services

    Samaritan Inns intends to provide at Tabitha's House are

    permitted as of right, and that they do not, in the District's

    view, make it a community-based residential facility. That

    conclusion is supported by the administrative law judge's

    decision of December 28, 1993, finding that Tabitha's House

    was properly classified as a rooming or boarding house rather

    than as a community facility, and by the BZA's decision not to

    revoke Tabitha's House's certificate of occupancy. Hence,

    there is no formal District policy or rule preventing Samari-

    tan Inns from making its planned use of Tabitha's House, and

    it is unclear what "accommodation" Samaritan Inns requests.

    The district court thus properly denied the request for relief.

    Accordingly, we reverse the judgment in part and remand

    the case for recalculation of Samaritan Inns' damages for

    delayed capital contributions arising from the District's inter-

    ference with the Next Steps Initiative, and for reconsidera-

    tion of the award for attorney's fees and costs; otherwise we

    affirm.


    Footnote: 1  

    1 Under the zoning regulations, a "boarding house" is "a build-

    ing or part of a building that provides, for compensation, meals or

    lodging and meals to three (3) or more guests on a monthly or

    longer basis." D.C. Mun. Regs. tit. 11, § 199.1 (1995).


    Footnote: 2  

    2 Under the zoning regulations, a "community-based residential

    facility" is "a residential facility for persons who have a common

    need for treatment, rehabilitation, assistance, or supervision in their

    daily living." D.C. Mun. Regs. tit. 11, § 199.1 (1995). If a facility is


    Footnote: 3  

    a community based residential facility, it cannot be deemed to

    constitute any other use permitted by the zoning regulations. Id.

    3 Under the zoning regulations, a "rooming house" is "a build-

    ing or a part of a building that provides sleeping accommodations

    for three (3) or more persons who are not members of the immedi-

    ate family of the resident operator or manager, and in which

    accommodations are not under the exclusive control of the occu-

    pants." D.C. Mun. Regs. tit. 11, § 199.1 (1995).


    Footnote: 4  

    4 See D.C. Mun. Regs. tit. 11, §§ 357-360 (1995) (defining

    permissible uses of various types of community-based residential

    facilities in R-5 zones).


    Footnote: 5  

    5 42 U.S.C. § 3602(h) provides:

    "Handicap" means, with respect to a person_

    (1) a physical or mental impairment which substantially

    limits one or more of such person's major life activities;

    (2) a record of having such an impairment, or

    (3) being regarded as having such an impairment,


    Footnote: 6  

    but such term does not include current, illegal use of or

    addiction to a controlled substance (as defined in section 802 of

    Title 21).

    Recovering alcoholics or drug abusers who do not currently use

    illegal drugs may be persons with a "handicap" under the Fair

    Housing Act. H.R. Rep. No. 100-711, at 22 (1988), reprinted in

    1988 U.S.C.C.A.N. 2173, 2183; see also United States v. Southern

    Management Corp., 955 F.2d 914 (4th Cir. 1992).

    6 42 U.S.C. § 3604(f)(1) makes it unlawful to:

    discriminate in the sale or rental, or to otherwise make unavail-

    able or deny, a dwelling to any buyer or renter because of a

    handicap of_

    (A) that buyer or renter,

    (B) a person residing in or intending to reside in that

    dwelling after it is so sold, rented, or made available; or

    (C) any person associated with that buyer or renter.

    42 U.S.C. § 3617 makes it unlawful to:

    coerce, intimidate, threaten, or interfere with any person in the

    exercise or enjoyment of, or on account of his having aided or

    encouraged any other person in the exercise or enjoyment of,

    any right granted or protected by section ... 3604 ... of this

    title.


    Footnote: 7  

    7 42 U.S.C. § 4604(f)(3)(B) provides that "[f]or the purposes of

    this subsection, discrimination includes ... a refusal to make rea-

    sonable accommodations in rules, policies, practices, or services,

    when such accommodations may be necessary to afford such person

    equal opportunity to use and enjoy a dwelling...."


    Footnote: 8  

    8 The district court found that the amount of this shortfall was

    $255,000. Erickson testified, however, that although the Tabitha's

    House campaign was $258,000 short of its goals at the time the

    stop-work order was issued, about $61,000 of that sum was already

    "in process," and thus, the total shortfall was approximately

    $196,000.


    Footnote: 9  

    9 The legislative history of the Fair Housing Act is "not too

    helpful." Trafficante v. Metropolitan Life Ins. Co., 409 U.S. 205 ,

    210 (1972); but see Gladstone Realtors v. Village of Bellwood, 441

    U.S. 91, 105-107 (1979). Although § 813 was added in 1988, its

    relief provisions are virtually identical to those in former § 812 of

    the original Fair Housing Act, Pub. L. No. 90-284, § 812, 82 Stat.

    88 (1968). The only significant differences between current

    § 813(c) and former § 812(c) are that the new provision eliminates a

    $1000 limit on punitive damages and broadens the court's discretion

    to award attorney's fees. See H.R. Rep. No. 100-711, at 39-40

    (1988), reprinted in 1988 U.S.C.C.A.N. 2173, 2200-01. Former

    § 812, like the remainder of the Fair Housing Act, derives primarily

    from an amendment offered on the Senate floor by the minority

    leader, Senator Dirksen. 114 Cong. Rec. 4570-73 (1968). The

    House ultimately agreed to the Senate amendments. Id. at 9621.

    Neither the House nor the Senate debates shed additional light on

    the meaning of the term "actual damages."


    Footnote: 10  

    10 Of course, knowledgeable donors might well be aware that

    the path of construction and renovation of facilities like Tabitha's

    House is rarely smooth, and that various obstacles are likely to

    arise during such endeavors. See, e.g., Linda Wheeler, Capitol Hill

    Residents Protest Opening of New Homeless Shelter, Wash. Post.,

    Jan. 30, 1996, at B3; Steve Bates, Alexandrians Fail to Stop Group

    Home, Wash. Post., July 18, 1996, at V1; Laurie Goodstein, A

    Mission Not All Will Embrace, Wash. Post. Oct. 21, 1993, at A1.


    Footnote: 11  

    11 Even if Erickson could not ascertain the intentions of all of

    its hoped-for donors to the capital campaign, the record demon-

    strates he had ongoing relationships with some of Samaritan Inns'

    key donors and could at least have determined their views.


    Footnote: 12  

    12 Erickson also testified that the Ward 4 Council Member had

    introduced legislation in the Council of the District of Columbia in

    1994 that would have made Tabitha's House a community-based

    residential facility. The measure was never enacted, and the

    District cannot be held responsible for the delay caused by the

    actions of an individual legislator.


    Footnote: 13  

    13 Because a remand is required, we note that Edelman ap-

    pears to have relied on the Consumer Price Index, a measure of

    inflation, rather than any measurement of interest rates, in making

    his damages calculations. While we do not now decide whether any

    particular method of calculating the income lost as a result of the

    delay is preferable to another, the district court should consider on

    remand whether Edelman's methodology is a reliable and appropri-

    ate way to measure Samaritan Inns' damages, and regardless of

    what methodology is used, the court should explain the basis for its

    choice. See generally St. Louis Southwestern Ry. Co. v. Dickerson,

    470 U.S. 409, 412 (1985); Jones & Laughlin Steel Corp. v. Pfeifer,

    462 U.S. 523, 536-42 (1983).


    Footnote: 14  

    14 Erickson's analysis indicated that he anticipated that Samari-

    tan Inns would receive $2,996,667 in 1994, $3,110,667 in 1995,

    $1,697,167 in 1996, and $195,500 in 1997.

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