Private Facebook Group Can Exclude Member–Khan v. ILONCA

The plaintiffs are a husband-wife couple, Khan and Abdulhamid. They are both Muslim and ethnically Middle Eastern. The plaintiffs bought a house in the Island Lake of Novi residential community in suburban Detroit. Halmaghi was the seller’s listing agent. The plaintiffs allege that Halmaghi made various racist remarks during the sales process. The husband posted a negative online review of Halmaghi. After that, Halmaghi kicked them out of the private Facebook group she administered called “Island Lake of Novi Residents.” The plaintiffs allege several connections between the Island Lake of Novi HOA and the private group, including that the HOA posts official notices there, which the plaintiffs couldn’t access. The plaintiffs sued the HOA and other defendants. The plaintiffs claimed Fair Housing Act and other anti-discrimination violations. The claims against the HOA fail mostly due to the pleadings’ lack of specificity about the HOA/private group linkages. As a result, this case…