Fair Housing

Under the New York State Human Rights Law, a housing provider's use of a criminal background check policy that categorically bars all persons with any criminal record from housing may:

AAlways be used because criminal history is not a protected class
BConstitute illegal discrimination if it has a disparate impact on a protected class (such as race) without being tailored to assess actual risk✓ Correct
CBe challenged only under the ADA
DBe used freely in New York City but not upstate

Explanation

New York's Division of Human Rights has issued guidance that categorical bans on persons with criminal records may constitute illegal discrimination if they disproportionately affect a protected class (particularly race) without consideration of the nature of the crime, time elapsed, or rehabilitation. Housing providers should conduct individualized assessments rather than blanket bans.

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