Watts v. Joggers Run Property Owners Association, Inc.

West Palm Beach, Palm Beach · federal · United States Court of Appeals for the Eleventh Circuit

MIXED · other

What happened

Sara Watts, an African American owner in Joggers Run (West Palm Beach), alleged the association treated her and her family worse than White neighbors regarding parking/towing, pets/service animals, and other enforcement. She sued under Fair Housing Act § 3604(b) and 42 U.S.C. §§ 1981 and 1982. The district court dismissed for failure to state a claim. On April 7, 2025, the Eleventh Circuit reversed and remanded, holding Watts plausibly stated claims under the FHA and §§ 1981/1982 and that the district court had construed those statutes too narrowly.

What the court (or agency) held

Mixed / member-favorable appellate procedural win—not a final liability judgment. Dismissal reversed; Watts’s race-discrimination allegations regarding association services/facilities and equal property rights were held plausible enough to proceed. Remanded for further proceedings.

Why this matters for members

This result is MIXED — a partial win, not a clean sweep on every claim. Selective enforcement framed as race discrimination can survive dismissal when pled with comparative neighbor treatment on parking, pets, and similar ‘services.’ Early wins may be remand-only; proof still must be developed. Boards should document evenhanded enforcement across households.

What the member did

Documented comparator treatment and board comments; pursued HUD then federal claims alleging selective enforcement and race discrimination tied to HOA membership privileges.

Questions for the board

Questions for a lawyer

Citation

Watts v. Joggers Run Property Owners Association, Inc., 133 F.4th 1032 (11th Cir. 2025); No. 22-13763 (2025-04-07). United States Court of Appeals for the Eleventh Circuit. Outcome chip: MIXED — FHA selective. Flags: MIXED, remand. Source: https://media.ca11.uscourts.gov/opinions/pub/files/202213763.pdf

_General information, not legal advice. Outcomes turn on facts and current law._

Source opinion

General information, not legal advice. Outcomes turn on facts and current law.

Not a law firm. Not legal advice. Confirm this against your documents and your state’s law.