Housing Provider’s Income Requirements Made Affordable Housing Unit Unavailable to Low-Income People

Affordable housing applicants denied due to restrictive income requirements that may disproportionately impact low-income Black and Hispanic renters

Attorney General Matthew J. Platkin and the Division on Civil Rights (DCR) announced a Finding of Probable Cause against Adoni Property Group, LLC, and its leasing agent, Legacy Realty Group, alleging discriminatory income policies that exclude low-income eligible renters. The DCR investigation found reasonable grounds to suspect that Adoni and Legacy’s minimum-income requirements violated the New Jersey Law Against Discrimination (LAD) by disproportionately excluding Black and Hispanic applicants from affordable housing.

The dispute stems from Adoni’s policy requiring applicants to have an after-tax monthly income at least three times the rent and a bank account balance five times the monthly rent. In this case, the complainant, a Black woman with two children, met state income guidelines for affordable housing but was disqualified under Adoni’s standards, which mandated a $3,933 after-tax monthly income and a $6,555 bank balance for the $1,311 monthly rent unit.

“Our civil rights laws prohibit housing providers from imposing screening barriers that result in discriminatory denials of housing to low-income New Jerseyans,” said Attorney General Platkin. “Protecting access to safe, stable, affordable housing has been a priority since I took office, and we will continue to hold accountable anyone who violates our laws.”

According to the LAD, neutral policies that disproportionately impact a protected class, such as those affecting racial or ethnic minorities, may still constitute unlawful discrimination. DCR’s investigation supported the claim that Adoni’s standards, while facially neutral, unfairly restrict Black and Hispanic applicants who represent a larger portion of Middlesex County’s low-income population.

The DCR’s findings emphasized that Adoni and Legacy’s minimum-income standards were not “well-tailored to predict future behavior relevant to tenancy,” per guidance from the U.S. Department of Housing and Urban Development. The investigation suggested that Adoni and Legacy could have employed less restrictive criteria, such as evaluating before-tax income, waiving bank balance requirements, or assessing rental history as evidence of payment reliability.

“New Jersey’s antidiscrimination laws are among the strongest in the nation. They prohibit housing providers from imposing tenant screening policies that have an unlawful disparate impact based on a protected characteristic,” said Sundeep Iyer, Director of the Division on Civil Rights. “Today’s announcement underscores that unduly restrictive minimum-income requirements may violate our antidiscrimination laws and can prevent renters, particularly low-income New Jerseyans, from accessing safe, affordable housing. We will continue to prioritize our enforcement work to dismantle unlawful barriers to housing across our state.”

The Finding of Probable Cause initiates a conciliation process for voluntary resolution. If no settlement is reached, the case may proceed to Superior Court or the New Jersey Office of Administrative Law, where a Deputy Attorney General would prosecute the claim on behalf of the DCR. This preliminary ruling does not determine final liability but signals the state’s commitment to equitable housing access in accordance with LAD protections.