Case Explained: 26a0185p.06

Court: United States Court of Appeals for the Sixth Circuit Filed: 2026-06-26 The sixth-circuit affirmed the district court’s dismissal of the Washingtons’ discrimination claims against First National Bank of Pennsylvania under the Fair Housing Act (FHA), the Equal Credit Opportunity Act (ECOA), Ohio state law, and the Americans with Disabilities Act (ADA). The court held that while the district court erred by requiring the plaintiffs to plead facts establishing a prima facie case of discrimination at the motion-to-dismiss stage, such an error was harmless because the complaint failed to meet the ordinary plausibility pleading standards established in *Bell Atlantic Corp. v. Twombly* and *Ashcroft v. Iqbal*. The court applied the standard that a plaintiff is not required to plead facts establishing a prima facie case under the *McDonnell Douglas* burden-shifting framework, as that framework is an evidentiary standard for summary judgment or trial, not a pleading requirement. Instead, the court reviewed whether the complaint contained sufficient factual matter to state a plausible claim for relief by allowing the court to draw a reasonable inference that the defendant discriminated against the plaintiffs based on race or disability. The court found the complaint insufficient because it relied on conclusory assertions that the bank treated other applicants differently without providing specific factual content regarding those comparators. Additionally, the court affirmed the dismissal of the ADA claim because the appellants failed to address the district court’s reasoning regarding that specific statute in their opening brief. The practical consequence is that the judgment of the United States District Court for the Northern District of Ohio dismissing the complaint is upheld, and the Washingtons’ lawsuit against the bank is terminated without leave to amend based on the current record. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.