Commonwealth Court of Pennsylvania upholds PHRC order


Commonwealth Court of Pennsylvania upholds PHRC order
Potter County landlord must pay more than $10,000 in disability discrimination case

HARRISBURG, PA – On Friday, January 5, the Pennsylvania Commonwealth Court upheld a Pennsylvania Human Relations Commission (PHRC) final order requiring Galeton, Potter County landlord Erin Jackson (“Jackson") to:

  1. Cease and desist from discriminating against anyone who requests a reasonable accommodation under the Pennsylvania Human Relations Act (PHRA);
  2. Cease and desist from retaliating against anyone who engages in protected activity under the PHRA;
  3. Pay the complainant a lump sum of $1,338.91, which represents reasonable out of pocket expenses incurred by the Complainant;
  4. Pay the complainant $6,000 in compensatory damages, which represents the embarrassment and humiliation the Complainant suffered, and which is directly attributable to Jackson's discriminatory and retaliatory actions;
  5. Deliver to the PHRC a check payable to the Commonwealth of Pennsylvania, in the amount of $3,000, which represents an assessment of a civil penalty pursuant to Section 9(f)(2)(i) of the PHRA.

Jackson, the respondent in the case, appealed the PHRC final order from December 2022, after the PHRC determined Jackson had unlawfully discriminated against a tenant by denying them an accommodation for a disability. The PHRC also found that Jackson retaliated against the tenant. The Commonwealth Court determined there was no error in the PHRC findings of unlawful discrimination and retaliation.

“The PHRA protects all Pennsylvania citizens from unlawful discrimination including disability," said PHRC Executive Director Chad Dion Lassiter, MSW. “PHRC is glad to see the Commonwealth Court of Pennsylvania uphold its decision to hold those who break the law accountable. PHRC hopes this ruling serves as an example to other landlords to follow the law."

In the court's concurring opinion, Judge Stacy Wallace said, “Whether a landlord has one tenant or one thousand, he or she must comply with the PHRA. A landlord would be wise to familiarize himself or herself with all legal obligations and consult an attorney."

The state's case was prosecuted by Stephanie Chapman, PHRC Assistant Chief Counsel.

“The PHRC's Office of Chief Counsel will always aggressively prosecute violations of the PHRA and hold Respondents accountable when they fail to comply with a Final Order of the PHRC," said PHRC Chief Counsel Meredith Millard, Esq. “Reasonable accommodations allow individuals, who otherwise would be prevented from obtaining housing, to have a place to live. Staff Counsel Chapman did an excellent job defending the PHRC's findings of unlawful discrimination and retaliation.

PHRC, the state's leading civil rights enforcement agency, urges anyone who has experienced acts of discrimination or hate to file a complaint with the PHRC by calling 717-787-4410.  Information and resources are also available at

PHRC Media Contact Details

Amanda Brothman

Communications Director 771-856-5971
Pennsylvania Human Relations Commission Media