Unreported / Non-Citable
Background
Mischa Adorare moved into a townhome owned and operated by Spillman Ranch Homes in September 2022. After a series of disputes, a Travis County court ordered her eviction in July 2024. Adorare pursued multiple complaints and lawsuits in Texas courts and administrative agencies concerning alleged harms arising from her tenancy.
Adorare sued Spillman in the Western District of Texas, asserting claims under the federal Fair Housing Act for failure to accommodate, discrimination based on race, gender, and disability, and retaliation. Following extensive motion practice, the district court granted summary judgment to Spillman, denied Adorare’s motion to set aside the judgment and her motion to recuse the district judge, and required her to obtain leave before filing additional motions.
The Court’s Holding
The Fifth Circuit affirmed. Reviewing the summary-judgment ruling de novo, the court concluded that no genuine dispute of material fact precluded judgment for Spillman. Because the case could properly be resolved on summary judgment, Adorare’s Seventh Amendment challenge also failed.
The court further held that the district court did not abuse its discretion in denying reconsideration under either Rule 59(e) or Rule 60(b), imposing the prefiling leave requirement as an exercise of its inherent docket-management authority, or denying recusal. Adorare forfeited her constitutional challenges to the filing restriction by raising them for the first time on appeal.
Key Takeaways
- Summary judgment did not violate the Seventh Amendment because no genuine dispute of material fact required a jury trial.
- The district court acted within its discretion in rejecting Adorare’s unsupported request to set aside the judgment and her motion for recusal.
- A court may require a litigant to obtain leave before filing additional motions as part of its inherent authority to manage its docket, and constitutional objections not raised below may be forfeited.
Why It Matters
The decision reinforces that Fair Housing Act claims must be supported by evidence creating a genuine factual dispute to survive summary judgment. Invoking the right to a jury trial does not prevent summary disposition when the evidentiary record presents no triable issue.
It also confirms district courts’ broad discretion to manage repetitive motion practice and illustrates the importance of preserving constitutional objections in the trial court.