The case is about determining if a single incident of harassment can create a hostile environment sex discrimination under the Fair Housing Act. Christina Brown filed a complaint against her landlord, Albert DiCenso, for sexual harassment and the Department found reasonable cause to believe that discrimination had occurred. The Administrative Law Judge initially ruled against Brown but the Housing and Urban Development Secretary's Designee disagreed and remanded the case for damages. The case was then reversed by the court.
The most relevant fact to the court's analysis is that DiCenso's conduct towards Brown, while unwelcome and harassing, was only a single incident.
DiCenso v. Cisneros (1996)
United States Court of Appeals for the Seventh Circuit
96 F.3d 1004
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