A Missouri landlord owns a four-unit building and lives in one of the units. He refuses to rent the remaining units to anyone of Irish descent, claiming it is a personal preference. A prospective tenant of Irish descent files a fair housing complaint. Under Missouri law, which of the following most accurately describes the legal outcome?
Correct Answer
C) The landlord is exempt from federal fair housing law but still violates the Missouri Human Rights Act based on ancestry
This is an expert-level trap. The Mrs. Murphy exemption under the federal Fair Housing Act (42 U.S.C. § 3603(b)(2)) does apply here — the landlord occupies one unit of a four-unit building and (assuming) uses no broker and no discriminatory advertising in the federal sense. So the landlord IS exempt from the federal Fair Housing Act. However, the Missouri Human Rights Act (RSMo Chapter 213) is a separate state statute with its own scope and exemptions. Missouri's MHRA includes ancestry as a protected class, and the MHRA's exemptions do not necessarily mirror the federal Mrs. Murphy exemption in the same way. The landlord's refusal based on Irish descent (ancestry) violates the Missouri Human Rights Act, even if federal liability is avoided. Missouri law provides independent state-level protection.
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