From the period of Nov. 5, 2017, to Dec. 3, 2021, Tatania Sellers, mother, post-office worker, and, at that time, a Connecticut resident, filed nine complaints with the Commission on Human Rights and Opportunities (CHRO) for lawful income discrimination. 

Throughout that period, Sellers and her lawyer, Tucker McWeeny, made at least $19,500 in settlements or mediation agreements. In the case of Richard Stefan, who did not agree to a settlement, he and his two brothers, Eric and Michael, were ordered on April 24, 2024, to pay Sellers $65,000 in compensation for emotional damages and loss of housing opportunities.

In each case Sellers made money on, the misstep that each losing landlord made was saying some variation of, “Sorry, we’re not accepting Section 8 tenants at this time.” 

In 1989, “lawful source of income” was added to Connecticut’s list of protected classes regarding housing and public accommodations. This change was intended to ensure that those who receive government assistance, whether through a program such as Section 8 or others such as SNAP, TANF, or Social Security, receive equal treatment when seeking housing. As a result, denying a tenant solely because of their Section 8 voucher is grounds for a discrimination complaint, which can be punished with steep fines. 

Even though this law has been on the books for 35 years, Bob DeCosmo, Executive Director of the Connecticut Property Owners Association, says that too many landlords he encounters don’t know about it.

“A lot of complaints that are going through the system are caused by needless errors by the landlord, who doesn’t understand the rules of the road,” DeCosmo told Inside Investigator in an interview.

Richard Stefan, who first made Inside Investigator aware of these complaints, argues that the law provides an easy opportunity for people to make money at the expense of landlords, describing the fines as “extortion.” Stefan argues that Sellers had no real intention of renting his property, but instead successfully used the letter of the law to extract money from him, calling her a “serial scammer.”

On the other hand, proponents of these protections, such as Michelle Dumas Kueler, Managing Director of CHRO’s Legal Division, say the protection is necessary to help ensure that Section 8 recipients aren’t locked out of housing. To her, one person filing numerous complaints doesn’t mean they’re intent on cashing in on landlords, but it shows the ubiquity of Section 8 discrimination.

“Somebody with a voucher could absolutely come upon five housing providers who say, ‘I don’t take Section 8’, and those are five complaints that they can file,” said Dumas Kueler. “That doesn’t make them some like serial filer who’s looking to, you know, benefit from this. It just means, unfortunately, they’ve come across some landlords who are not taking Section 8 vouchers.”

Sellers told Inside Investigator that she isn’t “gaming the system” to call out discrimination.

“It’s about protecting your right to housing,” said Sellers. “If someone broke the law by discriminating against me, how am I in the wrong for calling them out? No one says the same when landlords exploit legal loopholes to charge insane rents or evict people unfairly. I’m just making sure the system works the way it’s supposed to for everyone.”

Richard Stefan provided Inside Investigator with files on his own complaint, as well as files on other complaints filed by Sellers, which he retrieved via FOIA. The first two complaints, filed on Nov. 14, 2017, occurred after Sellers responded to a listing for a two-bedroom apartment in Norwalk, owned by Todd Grisham. Grisham was looking to rent out the apartment for $2,200 a month.  Sellers inquired if the unit was available and was put through to a realtor hired by Grisham, Kathryn Martino.

“Yes, the unit is available. What time works for you to view it? Deposit is two month’s rent. Thank you, Kathryn,” was her response, per the complaint.

Sellers responded by saying she had a Section 8 Housing Choice Voucher, to which Martino responded, “Unfortunately, this unit is not approved for Section 8.” On Nov. 14, 2017, Sellers filed two complaints with CHRO, one against Grisham, and another against Martino, alleging them of “refusal to rent; refusal to negotiate and discriminatory statement.”

“Respondent has discriminated against the Complainant solely because of her lawful source of income (Section 8),” read the complaint. “She was denied a valuable housing opportunity and suffered emotional distress reading the discriminatory statement.”

The outcome of the Grisham complaint is unknown, but paperwork shows that Martino ended up signing a predetermination conciliation agreement, in which she agreed to pay Sellers and McWeeney a total of $10,000.

Each of the case files followed a similar pattern. Not including the complaint against Martino, four of the complaints were withdrawn with settlements, three of them either the same day or the day after the complaint was filed. One of these settlements netted Sellers $7,000, and another netted $2,500. 

The complaints help patch together Sellers’ backstory. In the case analysis of Grisham’s complaint, it was said she originally received her Section 8 voucher in Pennsylvania. She said she moved to Connecticut to live closer to her mother. In the minutes Stefan provided of his CHRO damage determination hearing, held on Jan. 1, 2025, Sellers told CHRO Judge Komla Matrevi that she had a voucher for over ten years. Sellers also described the benefits the voucher has provided her.

“Honestly, it helped me a whole lot,” said Sellers. “I remember when I first even received my Section 8 voucher, I was so excited. I had my first daughter. My daughter was one, and I applied – I was in public housing first, and then I applied to the PA Housing Choice voucher program because it was open. I was calling and calling because, honestly, I believe still to this day that Section 8 is better than public housing because it gives us a little bit more opportunity and independence.”

Sellers went on to say that she appreciates her voucher because the type of housing it provides her access to allows her greater independence and privacy, that it has provided her with assistance in periods where she was without work, and that it has programs to assist with homeownership. 

Her only complaint with the voucher system, she said, is how landlords respond to it. 

“Some landlords, they don’t want to accept the Section 8 voucher,” said Sellers. “Some reasons they gave me is because, you know, some Section 8 tenants, I guess they previously had messed up the units or they hear [the] history of people – you know, Section 8 tenants don’t take care of the units or whatever the case may be.”

Sellers was living in a multifamily townhouse on Quinnipiac Ave with her two daughters when she first contacted Stefan on Dec. 3, 2021, with interest in his property. She described the neighborhood she lived in at the time as “okay,” but that she was looking to move closer to her place of employment. Sellers had been working for USPS in Norwalk, which was a 45-minute to an hour drive from her townhouse in New Haven. 

Stefan’s property, located on Arbor Drive in Norwalk, was only a 5–10-minute drive to her job, but was also appealing to Sellers for reasons beyond location. She said the kitchen was “gorgeous,” as was the neighborhood the house was in, and that she believed the area’s schools to be an upgrade from those in New Haven.

“I’m really mad I missed that opportunity, and he missed out on a good tenant,” said Sellers.

Sellers messaged Stefan on Facebook, first asking if the apartment was available, to which he said yes. She said Stefan let her know that she could take a tour of it if she liked, and it was at that point that she let him know about her voucher.

“I told him about my voucher because a lot of landlords, they deny Section 8 recipients, and I really didn’t feel like going to go see an apartment and wasting my time like I did before,” said Sellers.

Sellers went on to say that she felt as though sometimes “I have to prove myself” to landlords upon letting them know about her voucher. She said she was used to having to cite her employment or past housing history to try and persuade landlords to look past her voucher, saying that the voucher created a “little bit of a difference” in how landlords would view her.

Sellers said she reminded Stefan that it is against the law to deny an applicant housing solely based on their status as a Section 8 recipient, a reminder which he did not take kindly to.

“He said something in regard to, ‘I have been a landlord for so long,’ or something like that and, ‘I don’t have to take Section 8,’ and ‘I don’t take Section 8,’” said Sellers.

Sellers said that getting denied by Stefan made her feel, “less than, and I don’t ever want to feel like that again.” Sellers also shared the life difficulties she experienced at the time.

“First of all, the doctors – after I got denied, I found out I was pregnant,” said Sellers. “So that made it even worse, that put extra stress on my pregnancy because I was high risk, and then I couldn’t even work because I couldn’t even drive a whole hour to even get to work.”

Sellers said that the pregnancy was deemed high risk by her doctors in January 2022 and that she ended up losing her job in February because of her inability to make the long commute to work. Sellers ultimately ended up moving in September to a different apartment in New Haven. 

“If I would have gotten accepted to that unit, I would have stayed there for that year, and then I would have also had my job and my kids would still be in the better schools,” said Sellers. “I’m not saying my kids are not in a good school now, but, like I said, again, the schools in Stamford and Norwalk are way better than New Haven.”

Sellers said that the denial left her feeling stressed, anxious and depressed. She felt confused as to how her voucher could factor into Stefan’s decision-making process, saying she had good credit, a government job and a clean record.

“This doesn’t even make sense to me like that, it’s a whole government program to help,” said Sellers. “Why would you deny? I didn’t have anything — I don’t have a bad background; I had a job. Like there is nothing — there was no reason. No reason.”

When Stefan was provided the opportunity to question Sellers, he ran away with it. 

“I’ve got plenty of questions,” said Stefan. “You never called, you never showed up, you never did anything. You never made another attempt to rent another apartment in Norwalk.”

CHRO Attorney Libby Reinish told Stefan that “these are statements, not questions,” and the CHRO Judge presiding over the case, Komla Matrevi, had to cut Stefan off on several occasions.

“Mr. Stefan, hold one second,” said Matrevi. “Here’s what we’re going to do, alright?”

“This is a scam, Your Honor,” interrupted Stefan. “This is a scam, a government scam that I have uncovered.”

Stefan argued that Sellers’s complaint should be invalidated because she never called him, visited the property, or filled out an application. He accused her of lying under oath, said that he had lost $12,000 in rent over “falsified documents,” and attempted to bring in the other complaints to validate his point. Sellers responded by asking him a question of her own.

“I did not come to your unit because you said you wasn’t even accepting Section 8,” said Sellers. “Why am I going to waste my time or your time?”

At one point, Matrevi examined Stefan, asking him if he knew that it is “perfectly legal for someone to rent a house using a Section 8 voucher” in the state of Connecticut.

“Yeah,” said Stefan. “I mean, that’s understandable, but, you know, the truth is when she said she was a Section 8 — you know, I never heard of a government employee having a Section 8 voucher in my life. So, I just assumed she was lying or committing welfare fraud.”

In summation, Stefan’s argument was predicated on his belief that Sellers never truly intended to rent his apartment, that “she failed” to come by and plead her case to him, apply, or consent to a background check, and that she never provided him proof that she was a permanent employee. Stefan shared his doubt that Sellers lost her job because of his denying her housing, saying that if she did, it was because “it was a temporary job.”

Ultimately, the judge had to explain to Stefan that since he and his brothers had failed to provide CHRO with an answer to Sellers’s complaint within 15 days, the case had entered default. Essentially, the judge told Stefan that he had forfeited the case with his non-response, and that the only purpose of the hearing was to determine damages based on the assumption that all of Sellers’s allegations were true.

“Default basically means that you failed to answer, you failed to participate in the proceedings,” said Matrevi. “The law says whenever default is entered, we have to assume that all of the allegations are true. So, the story that Complainant Sellers is telling, the veracity is not really in question here.”

Filings show that the “veracity” of Sellers’ intent to rent was doubted in the Final Investigative Report of another complaint, filed by Sellers against Allyn and Marilyn Dodd on Nov. 20, 2018. The Dodds’ lawyer, Thomas Lambert, argued that the exchange between the two parties “seemed more like an exercise rather than really seeking the unit,” and that “the law requires more than a ‘tester.’”

“Tester” is a term used to describe those who pose as interested housing applicants but are instead just testing a landlord’s compliance with the Fair Housing Act (FHA), typically on behalf of a fair housing organization or government agency. The FHA, passed federally as a part of the Civil Rights Act of 1968, is what originally prohibited landlords from discriminating against tenants based on their protected characteristics (race, color, religion, sex, etc.). In 1988, the Fair Housing Amendment Act added national origin and disability discrimination to the list of federally protected characteristics. 

Lawful income discrimination is not enshrined in federal law, but has been passed into law in 23 states, and has been passed at the local level in over 140 municipalities and counties.

In the Sellers v. Dodds report, CHRO investigators admitted that “there is evidence to support” that Sellers was merely a tester, because she had four months left on her lease at the time of her application and because she told CHRO officials on Jan. 25, 2019, a few months later, that she had largely given up on her housing search. Sellers said she started looking for housing early because she had anticipated it might take a while to find, and said in January that “she did not have time to look and said that she wanted to get a three bedroom, so her children did not have to share a room.”

But ultimately, whether she was a tester or not is, by the letter of the law, irrelevant.

Dumas Kueler cited Havens Realty Corp v. Coleman, a 1982 Supreme Court case which set the precedent that testers can sue if they’re directly harmed by the discrimination taking place. In that case, a black tester, who had no true intent to rent an apartment, paired up with a white tester to ask for the availability of units at an apartment complex. The black tester was told there were no openings, while the white one was told there were. The court deemed that the misinformation fed to the black tester was considered a “distinct and palpable injury,” giving them grounds to sue. 

“Because of the Supremacy Clause, we would follow what the Supreme Court [does],” said Dumas Kueler. “A lot of the times, particularly with Section 8, and especially now in kind of these housing environments, people are communicating on their phones, and so they’re either sending text messages or they’re responding to ads, on Craigslist, or Facebook Marketplace, and so it’s its own kind of form of testing, in some ways, because everything’s written down, and so that ends up being its own evidence.”

While what constitutes a level of injury applicable to file suit as a tester can be contentious, especially when testing for ADA compliance, the Sellers v. Dodds report notes that, even if Sellers were one, it would not deny her outright the ability to file a complaint.

“Contrary to Attorney Lambert’s assertion, being a tester is sufficient for purposes of filing a discrimination complaint,” reads the report. “Respondents’ policy of refusing to rent to individuals with a Section 8 voucher is unlawful as is Respondents’ requirement that renters be employed. An employment requirement could preclude other lawful sources of income such as alimony, child support and/or Social Security Disability.”

Dumas Kueler explained the purpose of testing, saying that when she used to work for the Connecticut Fair Housing Center, it was crucial in determining cases of racial discrimination. 

“You would send testers out, and sometimes the Hispanic tester would not get a call back, because there was, you know, some kind of detection in the voice of an accent, whereas if you sent somebody who did not speak with an accent, that person would get an appointment,” said Dumas Kueler. “That’s not a situation where the person’s like, ‘Hey, I don’t rent to blah, blah, blah,’ but their actions are showing that they are not necessarily offering the showing of a unit to somebody who they discern is of a race, color, or national origin that they’re not interested in renting to.”

Typically, testers in the above scenario are picked to have matching backgrounds, credit scores, work and eviction histories, etc. to ensure that the only variable being controlled for is race, or some other protected characteristic. Testers, who usually work on behalf of an agency or organization, are also typically paid a fee per listing tested and work to provide evidence that establishes larger patterns of discrimination on behalf of the entity they work for. They do not typically act as solo operatives or lawyer-tenant duos, seeking settlement offers.

Several organizations in the state use and hire testers, including the Fair Housing Center, the Open Communities Alliance, and even CHRO itself. Even the federal government hires testers. In 1991, the Department of Justice’s Civil Rights Division established its own Fair Housing Testing Program. Per the DOJ, it has resolved 111 cases with evidence pulled from its testing program, recovering over $15.3 million in damages, since the program first began testing in 1992.

So, how is injury determined?

Stefan complained in his CHRO hearing that Sellers could not prove “a dollar’s worth of damage,” yet she wound up getting a reward of $65,000. Dumas Kueler said that injury in Connecticut’s state law is defined in Connecticut’s General Statutes, 46a-86.

“It could be actual cost, it could be emotional distress damages, it can be attorney’s fees and costs,” said Dumas Kueler. “For housing cases, if those cases go into Superior Court, the Commission, as a party, can ask for a civil penalty that goes back to the state, and the complainant can ask for compensatory out of pocket damages, emotional distress damages and punitive damages.”

Dumas Keuler said that emotional damages are typically determined based on a complainant’s testimony. In the CHRO’s final ruling in Stefan’s case, Matrevi cited a previous Connecticut ruling in the establishment of emotional distress damages and asserted that Sellers’ testimony met the definition.

“Here, Complainant provided a compelling testimony at the hearing in damages to show that she suffered emotional suffering, humiliation, and stress,” wrote Matrevi. “She testified that the Respondent’s conduct made her feel “less than” and she experienced stress, anxiety, and depression.”

Furthermore, Matrevi wrote that Stefan’s own testimony just wound up digging an even deeper hole for himself.

“I find that Respondent’s conduct was so egregious and offensive that it was meant to hurt and humiliate,” wrote Matrevi. “The Tribunal finds that the fact that Respondent was assuming that Complainant was lying or committing welfare fraud, by simply saying that she benefits from [the] Section 8 voucher program is enough to make his overall discriminatory conduct extremely offensive.”

Ultimately, Matrevi awarded Sellers $50,000 in damages on the basis of emotional distress, and $15,000 in damages for loss of housing opportunities.

Another avenue through which Sellers’ claims were disputed, both by Stefan and by the Dunns’ lawyer, was by assertions that her Section 8 voucher wouldn’t be able to cover their listed rent price. In a brief Stefan provided, he argued that his listing in Norwalk was a two-bedroom for more than $2,500 a month, citing a Facebook post Sellers put up 6 months after filing her complaint against him, in which she asked for leads on three to four-bedroom houses less than $1,900 a month. 

Essentially, he was arguing that she couldn’t have rented from him anyway, as her voucher wouldn’t cover the cost of his original listing. Dumas Keuler said that she has heard this argument from landlords herself, but said that “not every section eight tenant voucher holder is necessarily the same.” Dumas Keuler said that a landlord’s assumptions about what a Section 8 voucher will pay are never a valid excuse to deny them.

“They don’t know until the Housing Authority says what they’ll pay for, and so kind of guessing what the Housing Authority says they’ll pay for, and then saying no, based on what they believe the Housing Authority will pay for, is not something I would do,” said Dumas Keuler. “I always say to the landlords, ‘Let the Housing Authority tell you they’re not paying for this unit.’”

Both Sellers and Dumas Keuler explained that the same voucher can cover different amounts depending on the area it is being used in. Vouchers are dependent on a location’s “fair market” rent price. Dumas Keuler also mentioned that housing authorities may factor in characteristics like a tenant’s disability status when determining the rent a voucher will cover, adding further variance to the process.

“In this case, the property he listed for $2500 was in Norwalk, where the Section 8 payment standard actually aligns with that price point,” explained Sellers. “So even though I may have been looking for housing under $1900 in other areas, I could afford the $2500 rent in Norwalk through my voucher. That wasn’t a matter of personal budget — It was based on what Section 8 would cover in that specific area. His claim ignores how the program actually works.”

Dumas Kueler also said that she has had landlords ask her, just as Stefan has asked, how they can be charged with a complaint if the applicant didn’t go through the full application process, to which she posed nearly the same question as Sellers.

“Why would they go through the process of applying?” asked Dumas Keuler. “For places where they’ve already been told that you’re not going to take the source of income they use to pay their rent?”

Sellers told Inside Investigator that when she got her voucher, she was “excited at first, but reality hit quick.” She said that what she once thought would be a “golden ticket” to better housing opportunities, “just opened the door to a whole new form of rejection.”

“Even with the voucher, landlords wouldn’t return calls, show units, or would tell me outright,’ We don’t accept Section 8,”’ said Sellers. “The stigma is real. People assume you’re irresponsible, dirty, or looking for a handout. I understood that stigma as soon as I started applying and getting silence or lies in return.”

She shared the general process of getting a voucher and said it “isn’t easy.” Sellers said it can take years for a housing authority to accept your application, and once you’re accepted, there’s a screening process in which you must verify your income and have your background checked. When you get your voucher, you then have a limited window to find housing, which she described as typically being 60 to 120 days. 

She said that you also have to follow HUD’s rules, including staying within income limits, reporting changes in income or household composition, and keeping units in good condition.

“Noncompliance can get your voucher terminated,” she explained.

Sellers said that discrimination against voucher holders is “incredibly common,” and estimated that “at least half” of the landlords she’s reached out to either deny her outright or “make up excuses” when she tells them about her voucher.

“A lot of my friends on Section 8 face the same thing,” said Sellers. “It’s a huge barrier, even though the law says it shouldn’t be.”

Sellers said that her experience with landlords since getting her voucher has “been exhausting.”

“I’ve had to move multiple times, sometimes at the last minute, and I’ve spent so much time chasing leads that go nowhere,” said Sellers. “Financially, it’s been hard paying application fees for places that never had any intention of renting to me. And mentally, the constant rejection wears on you. You start to question your worth, even though it’s the system that’s broken.”

Sellers said that she discovered Connecticut had source of income protection after she started looking into housing law. She found Attorney McWeeny through recommendations and referrals from other tenants and advocates who had experienced the same issues as her.

“He has experience with housing discrimination, and he understands the system, which is important when you’re up against landlords with resources and legal teams,” said Sellers.

DeCosmo knew of McWeeny too, saying he used to work for CHRO, and then worked in defense of landlords when he first started his own private practice. DeCosmo said he “knows the laws as well as anybody in Connecticut.” 

Sellers said she has filed several complaints, and didn’t want to give an exact figure on how much she’s made, but said “it’s not like I’m getting rich from it.” She said that the settlements “barely make up for the time, stress, and the housing instability I’ve gone through.”

She believes that most landlords know the rules, “but they play dumb, hoping the tenant doesn’t push back.” She said that most landlords who have denied her seem to believe that Section 8 tenants are unreliable or will damage the property, and that their beliefs are “rooted in stereotypes.” She said that she pays her rent, keeps units clean and follows rules, but many landlords “don’t take the time to see that.” 

“As for what they say about me — I’ve heard it all,” said Sellers. “They call me a scammer, a troublemaker, but that says more about them than me. I’m just asking them to follow the law.”

While Sellers shared her belief that landlords stigmatize Section 8 tenants, DeCosmo said that “the only color that matters to landlords is green.”  What he thinks turns many landlords off from Section 8 isn’t the tenants themselves, but rather the bureaucracy associated with the program. 

“When I got into the business in the 1980s, we used to actively seek out Section 8 tenants when we had vacancies,” said DeCosmo. “When you look at the evolution of the program, it was an excellent program that really became so bureaucratic, a lot of people now will try to avoid the program, and the way they’ll do that is simply look at the market rate rents and ask higher than the program will pay.”

DeCosmo shared his belief that Section 8 needs streamlining. He said the standard to pass Section 8 inspections used to be “safe, decent and sanitary,” but over time has evolved into units needing to be “damn near perfect” or they would fail inspections. In addition to the rising standards, DeCosmo said that the program used to use local inspectors, but that it now hires private ones.

“Back in the day, you know, you get to know the inspector, he gets to know you, you can build up a relationship,” said DeCosmo. “He gets to know the reputation of the good guys, and they’d get a little bit of an easier time, and the ones who have a reputation of being not so good of a landlord, the inspection takes a little longer, it looks a little more into detail.”

He also believes fear of litigation among inspectors has increased, as they could be held liable if a safety hazard impacts the tenant and there is a finding that it should have been captured in the inspection.

“I think what’s happened is the fear of litigation has increased,” said DeCosmo. “So, if the inspectors go out to look at a unit – minor defects, like, for instance, say you have a cracked floor tile in the corner, where it’s not going to be a trip hazard but it’s just the tile needs to be replaced -they’ll fail the unit now, whereas before that would be something that’s, you know, it’s acceptable, safe.”

As a result, DeCosmo said that landlords who can’t afford to make the necessary renovations to pass a Section 8 inspection are placed between a rock and a hard place when a Section 8 tenant inquires about the unit’s availability.

“So, let’s say you’ve got some peeling paint on the outside of the house, and you know it’s not going to pass lead inspection,” said DeCosmo. “You tell the tenant, ‘Look, I don’t have the money to paint my house right now, but I know this is going to fail if the Section 8 program has to come out to inspect because I have some chipping and peeling paint on the outside’. Is that a legitimate excuse to deny the person?”

DeCosmo said situations such as those are some of the “unintended consequences” of making the living standards of Section 8 housing more stringent. Additionally, DeCosmo said that the state’s building codes and Section 8’s housing quality standards are often contradictory, and that the program is in desperate need of catching up with modern technology. He cited, as an example, that all communications between landlords and Section 8 administrators must be done either through fax or snail mail.

“If I’ve got a repair that needs to be done, I’m waiting on a fax or I’m waiting on a letter to be sent, where we could just simply take a digital photograph of the repair and email it to the landlord who could then immediately do the repair and email back,” said DeCosmo. “There’s a lot of inefficiencies right now.”

DeCosmo said that the commonly outsourced inspectors “might take two weeks of back and forth trying to get an inspection and a re-inspection,” a concern commonly cited by the landlords in the complaints filed by Sellers. Delays in a Section 8 inspection not only inconvenience the tenant looking to move in but also wind up delaying a landlord looking to receive a return on their units.

Issues surrounding Section 8 aside, DeCosmo said that landlords like those who settled with Sellers have only themselves to blame for not knowing the law. 

“I think they’re [new landlords] quick to grab those webinars and seminars on how to get rich quick, how to buy no money down, how to get off market deals, and they’re slow to learn the fair housing laws and discrimination issues, the companion pet issues, you know?” said DeCosmo. “So yeah, there’s certainly a gap between the ability to buy and the ability to operate.”

DeCosmo said that many of the landlords he’s encountered “tend to think they’re the kings of their own castles, and they’ll institute their own policies that may be afoul of the actual law.” DeCosmo said that in his experience, tenants are often better informed on fair housing laws than landlords, which he attributes to the prevalence of tenant advocacy organizations.

“It’s a little bit hard for us to educate, because we don’t have the money to generate the messaging,” said DeCosmo. “We’re actually talking about that internally, about seeing if we could become a non-profit and get some of the education, because again, a lot of these issues that you’re seeing people get cited for are completely avoidable had they had some prior knowledge of what the law was.”

DeCosmo didn’t voice any opposition to the state’s lawful income discrimination protections, but did claim that it allowed for “really unscrupulous people” to “make a hustle buck the easy way.”

“There are those out there gaming the system,” said DeCosmo. “Because certain landlords put in writing the refusal to accept, they’re dead to rights.”

Perhaps the most successful and substantive measure DeCosmo has taken in educating landlords on the topic was his suggestion to Rep. Larry Butler (D-Waterbury) in 2016 to propose a bill that requires purchasers of multifamily residential properties to receive a notice of federal and state fair housing laws. The bill was ultimately passed the same year.

“These are the laws, this is what you need to deal with, this is what you need to be aware of,” said DeCosmo. “When you’re buying a two-family house, you’re not just buying a house, you’re buying a small business to go along with it.”

On the topic of CHRO, DeCosmo said that the agency, which has long drawn the ire of landlords, has come a long way in improving its process. DeCosmo described the people he’s worked with over at CHRO as being “extremely professional,” but still insisted that the agency has shortcomings to improve upon. 

DeCosmo said that his main extant issues with CHRO are the fact that it has a lower burden of proof than civil court, and that the tenants themselves get what he described as “endless appeals.” He said that these two reasons alone lead him to advise other landlords facing CHRO complaints to just settle up front.

“The burden of proof that they’re up against, it’s ‘reasonable cause to believe,’” explained DeCosmo. “So, you know, in your wildest imagination, is it possible that this landlord may have discriminated?  Sure! Whereas if you go into the courts, its ‘preponderance of evidence.’”

DeCosmo talked about a case in which a landlord he knew received a housing discrimination complaint which Decosmo believed to be frivolous. He shared that the complainant was a member of the same exact protected class as the tenant that the landlord ended up renting the property out to, and that when the case was first reviewed, both HUD and the CHRO first dismissed it. The tenant appealed CHRO’s determination three times, until eventually it was overturned.

“Without any further investigation, a staff attorney at the Commission overruled the two previous reports over the HUD guidance that say, ‘Yes, discrimination occurred,’ and then it just went downhill from there,” said DeCosmo. “Cost the landlord $50,000 to fight them. Isn’t it easier to say, ‘Okay, you know, I’ll give you the $5000’ and be done with it?”

DeCosmo said that if a landlord wants to appeal a CHRO determination, it’s immediately brought to Superior Court, where the burden of proof is higher, making it more difficult for a landlord to overturn the ruling, as well as more costly. 

“So, the burden of proof to prove the case should be at a higher level, and at some point, there shouldn’t be endless reconsideration granted to the tenant,” said DeCosmo.

Dumas Keuler also pleaded her case as to why CHRO is structured the way it is. She said that the lower burden of proof required of CHRO is to expedite the method with which cases move through the system as opposed to higher courts. 

“The administrative forum is meant to be faster than court,” said Dumas Keuler. “That’s why we have an administrative forum, and it’s meant to be more accessible than court.”

Furthermore, Dumas Keuler stressed the fact that CHRO dismisses far more complaints than it admits, issuing more ‘no reasonable cause’ findings than not. According to CHRO’s 2023-2024 annual report, of the 2,439 complaints filed, only 74 ‘reasonable cause’ drafts were issued, and 77 cases were certified to proceed to a public hearing. 

Of the 2,218 complaints closed that year, CHRO made 321 ‘no reasonable cause’ determinations, while 388 complaints were closed either to ‘no claim for relief’ or ‘no possibility of reasonable cause finding.’ Notably, there were 745 withdrawals with settlement, making it the single most common complaint closer.

She also said the appeals system of cases works the exact same for both parties, in instances of complaints that go before a CHRO hearing, and that complainants only can ask for reviews of the initial ‘just cause’ or ‘no reasonable cause’ findings. Dumas Keuler said complainants get two reviews of the initial investigation findings, and then afterwards, the complainant must file an appeal to Superior Court. 

“If the landlord comes to the end of a public hearing case and they do not prevail, they can appeal it to Superior Court,” said Dumas Keuler. “Same with the complainant; If they come to the end of a public hearing case and they do not prevail, they can appeal to Superior Court.”

She said the two have “exactly the same” appeal rights at the end of public hearing cases, the only difference is that complainants get the ability to appeal initial investigation findings, because otherwise, “it’s the end of their case,” while the landlords “have won, effectively.”

Dumas Keuler also said that it’s “a common misperception” that CHRO provides representation for complainants, though admitted that it’s easy to understand why it’s confusing. She said that investigations surrounding complaints are done by “neutrals,” with the legal division not being involved.

“They work for the commission, but they are fact finders, and they find facts,” said Dumas Keuler. “They do not try to find facts for the complainant or try to find facts for the respondent. They are neutral.”

She said that where people often get confused is if a reasonable cause finding is issued and a complaint is brought to a hearing, CHRO gets entered as a third party to the complaint. She said that CHRO staff do not have attorney-client privilege with complainants, nor do they defend them.

“Our client is the state of Connecticut, it’s not the person,” said Dumas Keuler. “So we come in to represent and defend our discrimination laws on behalf of the state because there’s been an allegation of a violation of our statutes.”

She thinks the concept sometimes “gets conflated, and it gets confusing for housing providers,” and said that when cases are brought before CHRO referees, “we are on the complainant’s side of the ‘v’ because that’s where the allegations are of the discrimination statutes being violated, but we don’t represent them.”

“It’s confusing to the complainants,” chuckled Dumas Keuler. “This is not just a respondent issue, the complainant themselves will be like, ‘Don’t you represent me?’ it’s like, ‘No, we don’t represent you.’”

Dumas Keuler, who oversees training at CHRO’s Legal Department, said that CHRO holds quarterly trainings open to the public, and that they’re done live so that viewers can ask questions. She also said that they host a podcast every April on housing law. She explained that CHRO holds training sessions not only for employees, but for landlords, housing authorities and tenants.

“I train everybody,” said Dumas Keuler. “Everyone needs to know this information, it’s very important. In no way, do we want there to be some ‘gotcha’ moment, we want people to know what the laws are because we want them to be followed.”

Dumas Keuler also brought up Public Act 16-16, saying that the one-page fact sheet given to new owners of two-unit housing was to serve as an “appetizer.” 

“The concern was at the time that housing providers would buy housing they become landlords, and they think about all the landlord tenant statutes, or they think about all these other things, but they don’t necessarily think about fair housing as much,” said Dumas Keuler. 

Furthermore, Dumas Keuler wanted to highlight the fact that landlords are never forced to take Section 8 tenants and said that tenants could be lawfully denied for a variety of other reasons, such as poor credit or past evictions. The important part is that you allow them the same opportunity to apply as you would anybody else.

“They can go through all of the processes they normally would go through when vetting a tenant,” said Dumas Keuler. “What they can’t do is just be like, ‘Yeah, we don’t take Section 8.’”

DeCosmo viewed knowledge of the law with the same level of importance as Dumas Keuler, and said that CTPOA offers monthly webinars, with last month’s being on the issue of emotional support animals (another potential cause of housing discrimination complaints). DeCosmo said he has even had guests from CHRO and Section 8 on in the past to help explain Fair Housing laws.

DeCosmo encouraged landlords to learn the law before it’s too late, and said that by and large, landlords are “not proactive enough to gain the knowledge of the intricacies of the law, until it’s too late.”

“So, they get caught, that certified letter comes, and then they’re coming up and saying, ‘Help me,’” said DeCosmo. “My response is, you should have been here, you know, six months ago, for the webinar on discrimination, right?”

Dumas Keuler said that she was taught in her first week in law school that, “ignorance of the law is no defense.”

“If it’s published somewhere, it’s your obligation to know it,” she said.

As for Sellers, she said that she intends to use some of her settlement money on emergency savings, and to invest in long-term “safe, stable housing – something I’ve been fighting for all along.” Additionally, she is considering “investing in or partnering with landlords who are open to accepting Section 8, so that I can help expand access for others facing the same barriers I did.”

“If I can help create more housing opportunities, I will,” said Sellers. “The settlement isn’t just about money – it’s about accountability and using the outcome to push for something better, not just for myself but for others in the community too.”

Lastly, she wanted to dispel some of the stigma she thinks people have surrounding voucher holders.

“People need to understand that Section 8 isn’t a handout – it’s a safety net, and the discrimination people face while trying to use it is unjust and often illegal.” said Sellers. “I just want others in my position to know they have rights, and they don’t have to accept being treated like second-class citizens just because of how they pay their rent.”

As for Stefan, he told Inside Investigator that he has recently filed suit, hoping to overrule the decision made in Sellers’ complaint. The appeal, filed on June 5 in the New Britain Superior Court, concludes that CHRO decision was “flawed, inconsistent, contrary to the evidence, arbitrary, contrary to the law, and should not be upheld.”

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