IMU4: Unit 4 Definitions
HOUSING DISCRIMINATION SPRING 2008
INFORMATION MEMO ON UNIT FOUR
TABLE OF CONTENTS
(A) Unit Four: Covered Topics & List of Relevant Exam Questions
(B) Write-Up of Cardona Discussion Questions
(C) Write-Up of Statutory Drafting Discussion Groups (Prior Years)
(A) Unit Four: Covered Topics &
List of Relevant Old Exam Questions
(1) Definition of Race Under §1982: Old Exam Questions: 3B 3F 3Q
(2) Definition of “Marital Status” (Cohabiting Couples)
(a) See Assignment IV Comments/Model Answers
(b) Old Exam Questions 2B 3H 3M
(3) Definition of “Handicap” Under FHAA: Old Exam Questions: 3L 3R
(4) Statutory Drafting
(a) Working knowledge of principles and issues for Question II
(b) See Assignment IV Comments/Model Answers
(c) See Comments/Model Answers re Old Question Iis
(d) Write-up of statutory drafting discussion groups (see below)
(B) Write-Up of Cardona Discussion Questions
DQ 140. If you were litigating Cardona, what arguments would you have made for each side under St. Francis and Shaare Tefila?
For plaintiff
Under St. Francis? The Court considered the legislative history:
• “Congress, when it passed what is now §1981, had not limited its protections to those who today would be considered members of a race different from the race of the defendant. Rather, the legislative history of the section indicated that Congress intended to enhance ‘at the least, membership in a group that is ethnically and physiognomically distinctive.’” (middle of 2nd paragraph of St. Francis)
The Colombian plaintiff in the current case:
• Colombians are “ethnically and physiognomically distinctive” from Cubans – and at end of opinion Ct. states that “distinctive physiognomy” isn’t even necessary, so basically you just have to be facially ethnically different from accuser and alleged discrimination must be based on this – which it is.
Further legislative history:
• “These dictionary and encyclopedic sources are somewhat diverse, but it is clear that they do not support the claim that for the purposes of §1981, Arabs, Englishmen, Germans, and certain other ethnic groups are to be considered a single race.” (Beginning of 8th paragraph of St. Francis)
The Colombian plaintiff in the current case:
• Just as legislative intent deems Arabs & Englishmen different races for §1981 purposes even though they are currently both classified as Caucasian, so too does Congress agree that Colombians and Cubans are different races even though they share the native tongue of Spanish.
Under Shaare Tefila? The Court looks at legislative history to determine if Jews were intended by Congress to be protected:
• “As St. Francis makes clear, the question before us is not whether Jews are considered to be a separate race by today’s standards, but whether, at the time §1982 was adopted, Jews constituted a group of people that Congress intended to protect. It is evident from the legislative history of the section reviewed in St. Francis…that Jews and Arabs were among the peoples then considered to be distinct races and hence within the protection of the statute.” (last paragraph of Shaare Tefila)
The Colombian plaintiff in the current case:
• Same argument as in St. Francis – looks to intent of Congress and determines that even though Jews are Caucasians, they are not “foreclosed from stating a cause of action against other members of what today is considered to be part of the Caucasian race.” (last sentence of Shaare Tefila)
For defendant:
Under St. Francis?
Δ can argue… That §1981 does not provide for suits between Caucasians, as this was not stated in the statute nor clearly detailed in the legislative history – and for Ct. to allow this, Congress must first alter the statute b/c it’s their job, not the Ct.’s.
• However the ct. rejected this argument b/c at the time §1981 was enacted, Arabs were not considered Caucasians as they are now, and this goes against public policy anyway in preventing discrimination.
…That discrimination was merely on place of origin, the Middle East, rather than his belonging to a particular ethnic group.
• “If respondent on remand can prove that he was subjected to intentional discrimination based on the fact that he was born an Arab, rather than solely on the place or nation of his origin…he will have made out a case under §1981.” (last paragraph of St. Francis)
Under Shaare Tefila? Δ can argue... That since when are Jews considered a race? Judaism is a religion. Have you ever heard anyone refer to it as the “Jewish race”?
• The Ct. shouldn’t expand §1981&2 to encompass merely anyone that is different because that gives the government too wide a latitude to adjudicate private matters and decreases the overall sensitivity to discrimination by creating a windfall of discriminatory claims by anyone who feels discriminated against because they are of a different “group” than another person.
DQ141. The 1866 Congress mentioned neither Cubans nor Colombians. What kind of evidence might you introduce to demonstrate that the two groups should be considered separate races?
Actual evidence to introduce:
• Affidavits or witness testimony from unbiased South Florida Latinos (must be other than Cubans & Colombians) attesting to the Latin culture’s basic principle that to call Cubans & Colombians the same for §1981 purposes is clearly discriminatory.
• Ask the Amex Latin executives what they think, take a poll.
Policy arguments to introduce:
By not considering Cubans and Colombians distinct races, then you are ascribing to the overgeneralization of ethnicities as a way to circumvent a discrimination claim. Just because Chinese and Japanese are both Asian does not preclude a suit by a Chinese person claiming discrimination at the hands of a Japanese or Korean? You can not just create a broader group that both parties conveniently fit into, and disregard the more specific difference that is creating the racial animus.
In order to make it easier for people and the Court to feel empathy for a discrimination claim, consider two countries who would be considered non-“distinct” by Δ Amex’s contention, but who have been at war or have other special circumstances?
• What if a North Korean landlord refused to rent or promote any and all South Koreans? Or if Jordanians refused to rent to Israelis? Or if Syrians refused to rent to Lebanese?
• The majority uses polar opposite races in its decision, but even with more closely related (both in speech and geographic distance) groups like listed above, logic and legislative history dictates that a claim should not be precluded.
Where do you think Judge King got the information that supported his determination?
• Judge King used common sense from being culturally aware and knowledgeable.
• This is shown because the plaintiff never introduced evidence such as affidavits or witnesses (as discussed above), so there was nothing in the opinion citing such information from the record or lower courts’ decisions.
Would it be permissible for him to rely on his personal experiences living in South Florida?
I don’t think so. I think judicial fairness and impartiality requires him to go strictly by facts presented in the record or by previous cases in Florida regarding the proper classification of Cubans and Colombians, or other Latin ethnicities.
(D) WRITE-UP OF DRAFTING EXERCISES (PRIOR YEARS)
(1) Overview: Notes for Final Exam Question II
a. Before redrafting a passage in a statute, indicate what is wrong with it, so I can see what you are trying to accomplish with the redraft.
b. You need to be able distinguish between
(i) suggestions that make the statute clearer without changing what it does; and
(ii) suggestions that make substantive changes
c. Be specific. “The statute is vague.” may be true, but it’s not very helpful. In what way? If you think a word was used incorrectly, explain why.
(2) Advertising Amendment
Overview. This is former Exam Question 2G; more comments and good student answers are available online. You can improve this statute by restructuring it to recognize the difference between the first two provisions and the third. A nice example from one of the model answers:
For the purpose of this subsection, relevant factors may include –
(1) The selection of human models for discrimination claims based on race, color, national origin, or familial status.
(2) The particular form of media, location of distribution, or target audience.
Nothing in this subsection requires an advertiser to incur unreasonable expenses to include additional models or advertise in additional forms of media or locations.
The selection of human models appearing in a notice or advertisement shall be a relevant consideration, but only for claims that the relevant protected class is race, color, national origin, or familial status.
a. Technical Drafting Concerns
i) Include “statement” along with notice and advertisement to be consistent with 3604(c). (do same in §2)
ii) replace “shall be” with “is” (George)
iii) relevant consideration of what? Needs to be explained. (George; Ringo) While this is awkwardly drafted, it is helpful to remember it is becoming a part of §3604 so a court might just interpret it to mean a relevant consideration in determining liability under §3604(c).
iv) relevant is repeated. The second use is unnecessary and can be deleted. One prior group suggested the first “relevant” is ambiguous because the models can be relevant either to the defendant’s marketing strategy or to the plaintiff’s claim. However, in the context of a §3604(c) claim, there is no reason for it to refer to the defendant’s marketing. The problems here stem from a lack of clear organization, not from the use of “relevant.”
v) but only is unnecessary
vi) protected class is a term from McDonnell-Douglas analysis and is not defined in the statute. Can simply say “for claims based on …”
b. Substantive Concerns (outside scope of assignment): Both groups expressed concern at the decision to exclude religion (hard to show), sex, handicap. You could plausibly argue that people don’t expect to be able to discern handicap and religion from models and so the concerns that arise are likely to be infrequent and very subtle and therefore not worth pursuing. Similarly, very few advertisers will try to indicate (or will be perceived as indicating) a preference based on sex, and so it may not be worthwhile to allow the cause of action.
c. Sample Formulations and Fajer Comments
i) Selecting human models appearing in a notice or advertisement is a relevant consideration for discrimination claims based on race, color, national origin, or family status.. This is a big improvement in terms of clarity although I would replace “discrimination claims” with “claims under this subsection” to clarify that you aren’t trying to change the whole statute.
ii) The selection of human models appearing in a notice or advertisement shall be a relevant consideration when determining discriminatory intent, but only for claims that the protected class is a race, color, national origin, or family status. The problem with this formulation is that intent is unnecessary for a §3604(c) violation; I think the intent is to have the models be relevant to the ordinary reader test.
iii) The only relevant protected classes when considering claims based on selection of human models in a notice or advertisement are race, color, national origin and familial status. (Ringo) I think this is clearer than the original at expressing its purpose. I’m not wild about “protected classes,” which is not a term the statute uses.
iv) The selection of human models appearing in a notice or advertisement is a relevant consideration for claims based on race, color, religion, sex, familial status, or national origin. (George): Also clearer than the original ; good dropping the shall for is. Might want to limit “claims” to those brought under “this subsection.” Adding the other characteristics back in is a substantive change (See above).
The particular media or location in which a notice or advertisement is displayed or distributed and the likely audience that results from that also are relevant to determine if it is in violation of this subsection.
a. Technical Concerns:
i) Particular is unnecessary.
ii) results from that is very awkward. (Ringo). Might replace with “the likely resulting audience….”
iii) As noted above, the whole structure could be improved by creating a prefatory clause that says something like “Relevant considerations in assessing liability under this subsection include …”
iv) might eliminate the passive construction
b. Substantive Concerns (outside scope of assignment).
i) One prior group expressed concern that the use of relevant might be vague or give courts too much flexibility, particularly in combination with the existing language of §3604(c): “indicates a preference.” This really is a substantive complaint. Moreover, keep in mind that courts already employ the very open-ended “ordinary reader” test here. All this provision does is tell the judge that she must admit evidence of the particular media used because it is relevant to the ordinary reader test.
ii) “Amendment suggests it is important to consider media and intended audience of ad. While this may be important, should also consider what a reader outside of these classes would perceive of the ad.” (Ringo). I think this is an unnecessary concern, Nothing in the Amendment forestalls the use of the ordinary reader test. Saying that some additional factors will be relevant doesn’t foreclose the use of others.
c. Specific Formulations and Fajer Comments.
i) When selecting the type of media or location where a notice or advertisement is displayed or distributed is a relevant consideration in determining the likely audience that resulted.
A) Change to “When selecting …” doesn’t make sense. Changes the first part of the sentence from a thing that can be “relevant” into an incomplete action.
B) Overall change misunderstands what the provision is doing. Of course the location and media help determine the likely audience, but as drafted without the reference to “this subsection”, you haven’t made any of this relevant to the determination of liability under §3604(c).
ii) The media or location in which a notice or advertisement is displayed or distributed and the likely audience that results from such ad or notice also are relevant considerations to the violation of this subsection
A) Good eliminating the unnecessary particular and the awkward results from that. However, “such ad or notice” also is pretty awkward.
B) “relevant considerations to the violation” feels awkward.
iii) Targeting a specific audience by use of particular media or location is relevant to determine if an advertisement is in violation of this subsection. (Ringo) The restructuring certainly makes the sentence clearer. I worry that the passive construction at the beginning will lead to awkward debate (e.g., if you are trying to hit everyone except a particular group, is that targeting a specific audience? )
iv) A nice version from a prior model answer: The means by which any notice, statement or advertisement is communicated and the likely resulting audience shall be relevant in determining if such notice, statement or advertisement is in violation of this subsection.
It is a defense to an action relying on paragraphs (1) or (2) of this subsection that it is unduly expensive at the present time for the defendant to present more models or advertise in additional media or locations.
a. Technical Drafting Concerns
i) unduly expensive Many students argued on the exam thought that this phrase was too vague or needed to be defined. Keep in mind that courts utilize tests like “unreasonable” and “undue burden” all the time and are used to weighing pros and cons. You need to discuss why it might be preferable to have a less flexible standard, rather than assuming that these standards are inherently a problem.
ii) at the present time for the defendant: “present time” is unclear (Ringo; George) all this can be deleted without changing the sense of the passage.
iii) eliminate 2d passive construction: “It is a defense … that presenting more models or advertising in additional media or locations would be unduly expensive.”
iv) Make more specific the subsection to which the Amendment refers. (Ringo): I think this is unnecessary. This is an amendment to §3604(c); that is the subsection in question.
v) Don’t start with “it” – poor writing and is unclear. (George) This is a good general rule. However, statutes commonly word defenses in this way: “It is a defense to an action under this subsection that ….”
b. Questions re nature of “defenses:”
i) Defense of “unduly expensive”/“more models language” may not be a defense b/c don’t always need more models. (Ringo) Defenses often create narrow exceptions to statutes where defendants meet particular tests (as we’ll see when we do statutory defenses in a couple of weeks). Idea is there’ll be a defense in the narrow set of cases (i) where an advertiser’s liability turns on the lack of models of a particular race or age (ii) and where the defendant genuinely can’t afford to redo the ads or add more models.
ii) “defense” … is this absolute? How good is this defense? (Ringo). The normal understanding is that, where you meet the criteria for the defense, you win the lawsuit. Where the criteria count in your favor but are weighed against the criteria that count against you, we’ll call them “factors” rather than a defense.
c. Alternate formulations and Fajer Comments
i) The Defense to an action in paragraphs (1) or (2) is that the violator will incur undue expense in the presentment of more models or in advertising in additional types of media or locations. Good idea to eliminate passive voice altogether; and resulting minor rewrites generally are good. “The Defense” sounds like there’s only one. “Presentment” is unnecessarily formal.
ii) Undue expense is a defense to an action relying on paragraphs (1) or (2) of the subsection This is very elegant. It eliminates a whole lot of words and both passive constructions. Initially, I thought you needed to explain where the undue expense would be generated, but I think that is clear enough from context and from limiting the defense to the prior paragraphs. Nicely done.
(3) Redraft of §1982
a. Current version of §1982: Property rights of citizens. All citizens of the United States shall have the same right in every State and Territory, as is enjoyed by white citizens thereof to inherit, purchase, lease, sell, hold, and convey real and personal property.
b. Thoughtful Outline of Considerations (John)
I. Problems:
A. Must bar all racial discrimination
1. What are the rights of white citizens?
2. We should perhaps broaden the statute to be more inclusive
B. Jones private and public discrimination in sale or rental of property
1. So we should expand to include private as well as public discrimination?
2. Protecting people in private contracts
3. If add private to the redraft make it explicit
C. McDonald applies to all discrimination
1. Whites are included
2. Must make it more explicit—all should have equal rights
D. St. Francis incorporates ancestry
II. So what goes in place of as is enjoyed by white citizens?
A. Race, color, national origin, or any other related characteristics
B. Perhaps incorporate a three prong test a la §3604(h)?
1. Real discrimination
2. Perceived discrimination?
C. We could make 1982 a lot more like 1981—separate out what is protected, to make it as clear as possible
1. Still missing race and national origin
2. Bifurcate this—all citizens
3. Want to stay parallel
4. National origin not enough to cover ancestry
c. Sample Redrafts
John #1: All citizens of the United States, regardless of race, color, ancestry, national origin, or any other related characteristic shall enjoy the right to inherit, purchase, lease, hold, and convey real and personal property in governmental and nongovernmental actions.
1. Incorporating McDonald & St. Francis: I like including the four related characteristics: race, color, ancestry, national origin. I’m not sure whether “any other related characteristic.” is a good idea. Might think about what kind of cases you think might fall into the catch-all. *** Might want to reword to make explicit that you are protecting against discrimination on these bases.
2. Incorporating Jones: “in governmental and nongovernmental actions” is a little unclear; “actions” suggests lawsuits. Altogether, the sentence reads “shall enjoy the right to inherit … property in governmental or nongovernmental actions.” Doesn’t really make sense. Perhaps something like “free from interference from” governmental and non-governmental actors.
3. Other Concerns:
a. Might say “same rights to inherit …”
b. might keep jurisdictional phrase: in every State and Territory
John # 2:
a) Statement of equal rights. All citizens of the United States, regardless of race, color, ancestry, national origin, or any other related characteristic shall enjoy the right to inherit, purchase, lease, hold, and convey real and personal property.
b) Protection against impairment. The rights protected by this section are protected against impairment by nongovernmental discrimination and impairment under color of State law
1. Incorporating McDonald & St. Francis: same comments as John #1.
2. Incorporating Jones: Very good idea to take language right from §1981, although Congress used a very clumsy formulation
3. Other Concerns: Same as John #1
Paul: No private or public entity shall deprive any citizen of the United States, in every state and territory thereof, on the basis of ancestry or ethnic characteristics, of the right to inherit, purchase, lease, sell, hold, and convey real and personal property.
1. Incorporating McDonald & St. Francis: Reasonable to take “ancestry or ethnic characteristics” from St. Francis, although I’d add in race & color to make clear that they are covered. Good to say “on the basis of” to clarify what you are protecting.
2. Incorporating Jones: I really like “No private or public entity” although you might say “person” somewhere to clarify that it covers humans as well as business entities and municipalities.
3. Other Concerns: Need to be careful with jurisdictional phrase: “in every state and territory thereof.” I think that, because it’s stated in the negative, it should be “in any state…” Otherwise, nice work.
(4) DRAFTING EXERCISE 3 is the last sample Question II
See comments and models fordetailed discussion .
(5) DRAFTING EXERCISE: PRIOR YEAR.
This is Exam Question 2F, which has no model answer, so you may want to look through the discussion below for technique issues.
Theme Housing Statute:
(1) In rental housing, it is not a violation of §3604 to give preferences to current or potential tenants in Theme Housing (as defined below) whose presence furthers the theme of such theme housing.
(2) Theme Housing must meet the following four requirements:
(A) It has to contain no more than fifty dwelling units and must be housing no more than 100 individuals at any one time.
(B) There must be a clearly articulated theme that is made known to all applicants and residents.
(C) The theme must not be about excluding specific groups protected by the Fair Housing Act.
(D) Operators of theme housing must run regular programming available to all tenants that is focused on aspects of the theme and general interest programming shall be insufficient.
1. Suggestions: Part 1 :
a. “rental housing…”
i) not a phrase used elsewhere in the statute. Might refer to dwellings.
ii) references to tenants may be sufficient (E)
b. might clarify who can exercise this exemption: “an owner or manager offering dwellings for rent”
c. “(as defined below)” is unnecessary since the definition follows immediately. (R)
d. Although “presence” is undefined (P), I think it clear enough from context that it means “being a tenant in the theme house”
e. “furthers the theme of such theme housing” is very awkward and arguably vague
i) “theme housing” is repeated (R). Can rewrite as it is not a violation of §3604 to give preferences to current or potential tenants in Theme Housing whose presence furthers its theme.” (A) (E)
ii) “such” is rarely a good idea (E)
iii) might clarify “furthers” to make clear that this is to be judged from perspective of the owners/operators, so that court isn’t second guessing.
2. Suggestions: Part 2 (Generally):
a. “four” is unnecessary.
b. subparts should employ parallel construction.
c. if subparts are worded carefully, can simply say, “Theme Housing must:”, then follow with : “(A) contain no more than … (B) have a clearly articulated theme … etc. (E)
d. requirements don’t define “theme housing” clearly enough (P) (R) (S)
i) might provide illustrative list of examples of themes (R)
ii) might define “theme” (S)
e. need consistency of language:
i) “tenants” v. “individuals” v. “residents” (R)
ii) “potential tenants” v. “applicants” (R)
3. Suggestions: Part 2A:
a. Two different requirements here: maximum number of people and maximum number of units.
i) might put in separate clauses
ii) Rubies & Sapphires suggested that don’t need both and suggested replacing with occupancy restrictions. I have two concerns with this approach:
A) This is two different kinds of limits on how much housing can be affected. No more than 50 units can be made unavailable to those who don’t fit the theme. Housing for no more than 100 people can be affected. The limits preclude both a building that contains 75 singles and a building containing 40 quads.
B) replacing the separate limits with maximum occupancy requirements seems to me to place unnecessary limits on how the operators want to set up their housing. Why not allow 15 quads or 50 singles?
iii) The two parts of this should be in parallel structure. E.g., numbers should both be words or both numerals (P) (S)
iv) Amethyst version: "It has to contain no more than 50 dwelling units and 100 residents at any given time." Problem with this: can’t tell if “no more than” modifies just 50 or both 50 and 100. Could be read to require 100 residents.
b. Probably need to be clear about whether it has to be one building or complex.
c. “Has to” should be “must” to be consistent with rest of amendment. (E)
d. “must be housing no more than 100 individuals”
i) Shouldn’t use “housing” as a verb when it is also used as a noun.
ii) “individuals” should be “persons” or “residents” (P)
ii) “may have up to 100 residents” may better capture the idea. (E)
e. “at any one time” probably adds nothing and can be deleted (E)
4. Suggestions: Part 2B:
a. Might separate out the two requirements created here: (1) existence of explicit theme; (2) notification
b. Two levels of passive voice here; could eliminate one or both.
i) One version: "All applicants and residents must be clearly informed of the theme." (A) Note that this treats “clearly articulated” as an indication of the mode of informing tenants rather than as a separate requirement about the theme.
c. Might try to clarify how management will notify applicants/residents (A) (E) (P) (S), although this is arguably a substantive change.
i) could require a “detailed description of theme in application.” (A)
ii) could require posting of theme
iii) could require in advertising for the house (P)
iv) could use an inclusive list of how to do (S) (good idea)
5. Suggestions: Part 2C:
a. The author wants to make sure that the theme is not the exclusion or inferiority of some group of people defined by one or more of the listed characteristics. Capturing this is the hardest part of this assignment.
b. “must not be about excluding” is both awkward and vague.
i) Sapphires noted that you could create a theme for “White Supremacist House” in way that did not focus on “excluding.”
ii) Amethyst version: “The theme cannot exclude . . .” I think this is problematic because the theme may not be the agent for exclusion.
iii) Rubies suggested that the clause be rewritten to focus on what can be allowed, but I think you need some indication of the negative to get at the distinction the author wants to make.
c. “specific groups protected by the Fair Housing Act” doesn’t really capture intended idea. Everyone is protected by FHA. (E)
i) should clarify: group of people defined by one or more of the listed characteristics.
ii) might want to focus on members of groups. (A).
iii) One suggestion: “Nothing in this subchapter shall be construed to permit determinations on the basis of race, sex …” This is a problem, because the point of the amendment is to allow some discrimination on the basis of, e.g., national origin, to further the theme.
6. Suggestions: Part 2D:
a. Needs definitions:
i) Define “regular” (E) (P)
ii) Define “programming” or give inclusive list of examples (P) (S)
iii) Define “operator” (E)
b. “general interest programming shall be insufficient” is probably unnecessary given the requirement of programming “focused on aspects of the theme.” (R)
7. Diamond Redraft of Statute (and my comments):
It is not a violation of 3604 to give preferences to current or potential tenants in “theme housing.’’ “Theme housing’’ shall be read to mean:
(1) Any housing at an educational institution with an organization whose members are of like ethnicity and
(2)Whose organizations have no historical background of discrimination against other groups in the United States.
Members and officers of theme housing shall not exclude non-members of the group who express a sincere interest in living in the theme housing and following all applicable rules and regulations of the housing.
a. good idea to define “theme housing”
b. “shall be read to mean” is quite wordy; “means” is fine
c. need to explain what kind of “preferences” are allowed; would seem to allow any kind of preferences at all.
d. Tie to “educational institution” is plausible but not what was in the original version. Need some kind of definition (Is a monastery? Barnes & Noble? the Coast Guard?).
e. “with an organization…”:
i) need to clarify that the housing has to be related in some fashion to the organization. As written, any housing at any university (surely they all have some ethnic organizations) would qualify.
ii) nothing in original proposal limits to single ethnicity themes
f. “whose organizations”: need to clarify that you mean specific organization that is running the housing, not all ethnic orgs at university. Otherwise, if any one of them had such a history, no theme houses at all.
g. “non-members of the group”: what group? no prior references
h. “shall not exclude”: too broad. Means that you have to let them in even if they have bad credit and criminal record and house is already full. Need to figure out how to allow some preferences while still limiting exclusion.
i. “sincere interest in living in the house”: not clearly necessary; surely they won’t agree to live in the house unless they sincerely want to.
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