Robyn Halprin & Rick Halprin v. The Prairie Single Fam. Homes of Dearborn Park Ass'n, 388 F.3d 327 (7th Cir. 2004). · Go Syfert
Robyn Halprin & Rick Halprin v. The Prairie Single Fam. Homes of Dearborn Park Ass'n, 388 F.3d 327 (7th Cir. 2004). Cases Citing This Book View Copy Cite
“e do not want, and we do not think congress wanted, to convert every quarrel among neighbors in which a racial or religious slur is hurled into a federal case.”
203 citation events (203 in the last 25 years) across 36 distinct courts.
Strongest positive: Park Crossing Homeowners Association Inc. and Martha Fernandez v. Ivonne Suarez (fladistctapp, 2025-04-30) · Strongest negative: Cox v. City of Dallas Texas (ca5, 2005-11-09)
Treatment trajectory · 2004 → 2026 · click a year to view as-of
2004 2015 2026
Top citers, strongest first. 50 distinct citers.
examined Cited "but see" Cox v. City of Dallas Texas (3×) also: Cited as authority (rule)
5th Cir. · 2005 · signal: but see · confidence high
Trust v. Dep’t of Consumer and Regulatory Affairs, 257 F.Supp.2d, 208 (D.D.C.2003); but see Halprin, 388 F.3d at 329 (denying § 3604(a) claim where plaintiffs "are complaining not about being prevented from acquiring property but about being harassed by other property owners” (emphasis added)). 20 .
discussed Cited as authority (verbatim quote) Park Crossing Homeowners Association Inc. and Martha Fernandez v. Ivonne Suarez
Fla. Dist. Ct. App. · 2025 · quote attribution · 1 verbatim quote · confidence high
the fair housing act contains no hint either in its language or its legislative history of a concern with anything but access to housing.
discussed Cited as authority (verbatim quote) FAIR HOUSING CENTER OF CENTRAL INDIANA, INC. v. RAINBOW REALTY GROUP, INC.
S.D. Ind. · 2020 · quote attribution · 1 verbatim quote · confidence high
the language indicates concern with activities, such as redlining, that prevent people from acquiring property.
discussed Cited as authority (verbatim quote) Zafar Sheikh v. David Rabin
7th Cir. · 2014 · signal: see also · quote attribution · 1 verbatim quote · confidence high
e do not want, and we do not think congress wanted, to convert every quarrel among neighbors in which a racial or religious slur is hurled into a federal case.
discussed Cited as authority (verbatim quote) Davis v. Wells Fargo Bank (2×) also: Cited as authority (rule)
N.D. Ill. · 2010 · quote attribution · 1 verbatim quote · confidence high
as a purely semantic matter the statutory language might be stretched far enough to reach a case of ... 'attempted constructive eviction.
examined Cited as authority (verbatim quote) Savanna Club Worship Service, Inc. v. Savanna Club Homeowners' Ass'n (3×) also: Cited "see, e.g."
S.D. Fla. · 2005 · quote attribution · 1 verbatim quote · confidence high
we do not think that congress wanted, to convert every quarrel among neighbors in which a racial or religious slur is hurled into a federal case
discussed Cited as authority (rule) Stowe (2×) also: Cited "see, e.g."
M.D. Fla. · 2025 · confidence medium
Homes of Dearborn Park Ass’n, 388 F.3d 327, 329 (7th Cir. 2004)).
cited Cited as authority (rule) Burley v. Chapman
N.D.N.Y. · 2025 · confidence medium
Homes of Dearborn Park Ass’n, 388 F.3d 327, 330 (7th Cir. 2004); Ohana v. 180 Prospect Place Realty Corp., 996 F. Supp. 238, 243 (E.D.N.Y. 1998).
discussed Cited as authority (rule) Doe v. University Of Idaho
D. Idaho · 2024 · confidence medium
Instead, this Court notes that courts addressing conduct under FHA have concluded “interference” under § 3617 “is more than a ‘quarrel among neighbors’ or an isolated act of discrimination, but rather is a ‘pattern of harassment, invidiously motivated.’” Bloch v. Frischholz, 587 F.3d 771, 783 (7th Cir. 2009) (quoting Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 330 (7th Cir. 2004)). “[A] plaintiff cannot rely on § 3617 for trivial or isolated disputes.” Hatfield v. Cottages on 78th Comty.
cited Cited as authority (rule) McGrath v. Dunecrest Condominium Association
N.D. Ind. · 2024 · confidence medium
Homes of Dearborn Park Ass’n, 388 F.3d 327, 330 (7th Cir. 2004) (defining interference as “a pattern of harassment, invidiously motivated”).
discussed Cited as authority (rule) Bass v. Brannen
N.D. Ill. · 2024 · confidence medium
Homes of Dearborn Park Ass’n, 388 F.3d 327, 330 (7th Cir. 2004) (noting cases where sexual harassment and economic pressure rose to the level of “interference” under § 3617).
cited Cited as authority (rule) Meadows v. Buffalo Police Department
W.D.N.Y. · 2024 · confidence medium
Homes of Dearborn Park Ass’n, 388 F.3d 327, 330 (7th Cir. 2004).
cited Cited as authority (rule) Trujillo v. Amity Plaza LLC
D. Colo. · 2024 · confidence medium
Halprin v. Prairie Single Family Homes of Deerborn Park Ass’n, 388 F.3d 327, 329 (7th Cir. 2004).
discussed Cited as authority (rule) Lavela, Gormidou v. Peloquin, Aaron (2×) also: Cited "see, e.g."
W.D. Wis. · 2023 · confidence medium
Homes of Dearborn Park Ass’n, 388 F.3d 327, 330 (7th Cir. 2004); cf. Wilson v. Warren Cnty., Ill., 830 F.3d 464 , 467–68 (7th Cir. 2016).
discussed Cited as authority (rule) Meadows v. Buffalo Police Department (2×) also: Cited "see"
W.D.N.Y. · 2023 · confidence medium
Homes of Dearborn Park Ass’n, 388 F.3d 327, 330 (7th Cir. 2004).
examined Cited as authority (rule) Tonca Watters v. Homeowners Association at the (3×) also: Cited "see"
7th Cir. · 2022 · confidence medium
Homes of Dearborn Park Ass’n, 388 F.3d 327, 330 (7th Cir. 2004); see also Revock v. Cowpet Bay West Condominium Ass’n, 853 F.3d 96 , 112–13 (3d Cir. 2017) (“A Section 3617 interference claim re- quires … a causal connection existed between the exercise or enjoyment of the right and the defendant’s conduct.”); Scaife v. Cook Cnty., 446 F.3d 735, 741 (7th Cir. 2006) (applying the nexus requirement in the Title VII context), overruled on other grounds, Hill v. Tangherlini, 724 F.3d 965 , 967 n.1 (7th Cir. 2013).
discussed Cited as authority (rule) Huzjak v. Ellis
E.D. Wis. · 2021 · confidence medium
However, “[n]either the FHA’s text nor its legislative history indicates an intent to make ‘quarrels between neighbors … a routine basis for federal litigation.’” Bloch v. Frischholz, 587 F.3d 771, 780 (7th Cir. 2009) (quoting Halprin v. Prairie Single Family Homes of Dearborn Park Ass'n, 388 F.3d 327, 329 (7th Cir. 2004)).
discussed Cited as authority (rule) Mabry v. City of East Chicago (2×)
N.D. Ind. · 2021 · confidence medium
Homes of Dearborn Park Ass'n, 388 F.3d 327, 330 (7th Cir. 2004).
discussed Cited as authority (rule) Wallace v. Greystone at the Highlands Association
W.D. Mich. · 2020 · confidence medium
See, e.g., Francis v. Kings Park Manor, Inc., 917 F.3d 109, 114-15 (animus where defendant made multiple violent threats on multiple occasions while using slew of racist and anti-Semitic epithets); Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 330 (7th Cir. 2004) (animus where vandalism included writing referencing plaintiff’s Jewish faith on plaintiff’s wall). 2.
discussed Cited as authority (rule) Abdelhalim v. Lewis (2×) also: Cited "see, e.g."
E.D. Va. · 2020 · confidence medium
Without any express unlawful discrimination or slurs of any kind, Plaintiff's claims certainly cannot stand where “we do not think Congress wanted[] to convert every quarrel among neighbors in which a racial or religious slur is hurled into a federal case.” Halprin v. Prairie Single Family Homes of Dearborn Park Ass'n, 388 F.3d 327, 330 (7th Cir. 2004).
cited Cited as authority (rule) Black v. Friedrichsen
N.D. Ind. · 2020 · confidence medium
Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 330 (7th Cir. 2004).
discussed Cited as authority (rule) Francis v. Kings Park Manor, Inc. (2×)
2d Cir. · 2019 · confidence medium
First, as Judge Posner noted some years ago when analyzing the provision at issue here, “[t]he Fair Housing Act contains no hint either in its language or its legislative history of a concern with anything but access to housing.” Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 329 (7th Cir. 2004).
examined Cited as authority (rule) Treece v. Perrier Condominium Owners Association, Inc. (3×)
E.D. La. · 2019 · confidence medium
The court determined the two statements made during the process of renting the apartments were actionable under § 3604(c) but the two statements made outside the 94 Meadowbriar Home for Children, Inc. v. Gunn, 81 F.3d 521, 531 (5th Cir. 1996). 95 Cox v. City of Dallas, 430 F.3d 734, 741 (5th Cir. 2005) (citing Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 329 (7th Cir. 2004)). 96 Id. 97 Cox, 430 F.3d at 741 . 98 Kelly, 364 F. Supp. 3d at 654. 99 Id. 100 Id. at 641 . rental process were not.101 In reaching this conclusion, the court in Kelly referenced a case i…
cited Cited as authority (rule) WATTERS v. HOMEOWNERS ASSOCIATION AT THE PRESERVE AT BRIDGEWATER
S.D. Ind. · 2019 · confidence medium
Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 330 (7th Cir. 2004).
discussed Cited as authority (rule) Gilead Community Services, Inc. v. Cromwell
D. Conn. · 2019 · confidence medium
Additionally, as some courts have held, “[i]t is sufficient to state that ‘interference’ under [§ 3617] can encompass a ‘pattern of harassment, invidiously motivated.’” Middlesex Opportunity Council, 752 F. Supp. 2d at 85 , 104 (quoting Halprin v. Prairie Single Family Homes, 388 F. 3d 327, 330 (7th Cir. 2004)).
discussed Cited as authority (rule) Gilead Community Services, Inc. v. Cromwell
D. Conn. · 2019 · confidence medium
Additionally, as some courts have held, “[i]t is sufficient to state that ‘interference’ under [§ 3617] can encompass a ‘pattern of harassment, invidiously motivated.’” Middlesex Opportunity Council, 752 F. Supp. 2d at 85 , 104 (quoting Halprin v. Prairie Single Family Homes, 388 F. 3d 327, 330 (7th Cir. 2004)).
discussed Cited as authority (rule) Barot v. Aldon Management
D.D.C. · 2019 · confidence medium
While some courts have found that § 3604(b) does not extend to discriminatory conduct interfering with an individual’s use of property after the property was leased or sold, see, e.g., Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 329 (7th Cir. 2004); see also Clifton Terrace Assocs., Ltd. v. United Techs.
discussed Cited as authority (rule) Francis v. Kings Park Manor, Inc. (2×)
2d Cir. · 2019 · confidence medium
Because the FHA's central focus was "the widespread practice" in 1968 "of refusing to sell or rent homes in desirable residential areas to members of minority groups," post-acquisition problems including " harassing ... neighbors " would "tend not to arise until the Act was enacted and enforced." Id. at 328-29 (emphasis added).
discussed Cited as authority (rule) National Fair Housing Alliance v. Deutsche Bank National Trust
N.D. Ill. · 2018 · confidence medium
City of Modesto, 583 F.3d at 712 (citing Bloch v. Frischholz, 533 F.3d 562, 563-64 (7th Cir. 2008), reversed and remanded in unrelated part on rehearing en banc, Bloch v. Frischholz, 587 F.3d 771, 787 (7th Cir. 2009); Halprin v. Prairie Single Family Homes of Dearborn Park Assoc., 388 F.3d 327, 329 (7th Cir. 2004)).
discussed Cited as authority (rule) Marsha Wetzel v. Glen St. Andrew Living Communi (2×) also: Cited "see, e.g."
7th Cir. · 2018 · confidence medium
(We confess to having trouble seeing the act of throwing an elderly person out of a motorized scooter as one of the or‐ dinary problems of life in a senior facility.) Wetzel has pre‐ sented far more than “a simple quarrel between two neigh‐ bors or [an] isolated act of harassment.” See Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 330 (7th Cir. 2004).
discussed Cited as authority (rule) Marsha Wetzel v. Glen St. Andrew Living Communi (2×) also: Cited "see, e.g."
7th Cir. · 2018 · confidence medium
(We confess to having trouble seeing the act of throwing an elderly person out of a motorized scooter as one of the or‐ dinary problems of life in a senior facility.) Wetzel has pre‐ sented far more than “a simple quarrel between two neigh‐ bors or [an] isolated act of harassment.” See Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 330 (7th Cir. 2004).
discussed Cited as authority (rule) Shaw v. Williams (2×) also: Cited "see"
N.D. Ill. · 2018 · confidence medium
Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 330 (7th Cir. 2004) Plaintiff claims that he engaged in protected activity when he requested accommodations between March and July 2014. [175] at 9.
discussed Cited as authority (rule) Viens v. America Empire Surplus Lines Ins.
D. Conn. · 2015 · confidence medium
The Seventh Circuit has read the statute more narrowly, concluding that the text of the FHA “indicates concern with activities, such as redlining, that prevent people from acquiring property” and “contains no hint either in its language or 'Its legislátive history of a concern with''anything but access to housing.” Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 329 (7th Cir.2004).
discussed Cited as authority (rule) Ohio Civ. Rights Comm. v. Myers
Ohio Ct. App. · 2014 · confidence medium
Halprin v. Prairie Single Family 17 Homes of Dearborn Park Assn., 388 F.3d 327, 329-30 (7th Cir.2004). {¶ 38} Myers argues that, even if claims against neighbors can be made under R.C. 4112.02(H), the allegations in the complaint are insufficient to state a claim against him. {¶ 39} Accepting the allegations in the complaint as true and construing them in the light most favorable to the Commission, Myers “harassed and intimidated” Podiak and her animal assistants due to Podiak’s disability.
cited Cited as authority (rule) Hidden Village, LLC v. City of Lakewood, Ohio
6th Cir. · 2013 · confidence medium
Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 330 (7th Cir.2004).
examined Cited as authority (rule) Wells v. Rhodes (3×) also: Cited "see"
S.D. Ohio · 2013 · confidence medium
The Court also recognizes, however, authority stating that the FHA was not designed “to convert every quarrel among neighbors in which a racial or religious slur is hurled into a federal case.” Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 330 (7th Cir.2004).
examined Cited as authority (rule) Hidden Village, LLC v. City of Lakewood (3×) also: Cited "see"
N.D. Ohio · 2012 · confidence medium
Id. at 298-99, 302 (citing to Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 329-30 (7th Cir.2004) and Cox v. City of Dallas, 430 F.3d 734, 740-41 (5th Cir.2005)).
discussed Cited as authority (rule) Stevens v. HOUSING AUTHORITY OF SOUTH BEND, IND.
7th Cir. · 2011 · confidence medium
We noted in Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 329 (7th Cir.2004), that the Fair Housing Act is aimed generally at access to housing and does not address post-acquisition discrimination.
discussed Cited as authority (rule) South Middlesex Opportunity Council, Inc. v. Town of Framingham
D. Mass. · 2010 · confidence medium
It is sufficient to state that “interference” under the statute can encompass a “pattern of harassment, invidiously motivated.” Halprin v. Prairie Single Family Homes, 388 F.3d 327, 330 (7th Cir.2004).
cited Cited as authority (rule) Bloch v. Frischholz
7th Cir. · 2009 · confidence medium
This harassment did not give rise to an FHA claim, we concluded in Halprin , because the FHA by and large concerned only “access to housing.” Id. at 329 (emphasis in original).
cited Cited as authority (rule) Lynne Bloch v. Edward Frischholtz
7th Cir. · 2009 · confidence medium
This harassment did not give rise to an FHA claim, we concluded in Halprin, because the FHA by and large concerned only “access to housing.” Id. at 329 (emphasis in original).
examined Cited as authority (rule) AHF COMMUNITY DEVELOPMENT, LLC v. City of Dallas (3×) also: Cited "see"
N.D. Tex. · 2009 · confidence medium
Id. (quoting Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 329 (7th Cir.2004) (fourth alteration added)).
cited Cited as authority (rule) Fincher v. South Bend Housing Authority
N.D. Ind. · 2009 · confidence medium
C.f, Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 329 (7th Cir.2004) (suggesting that the FHA has no language providing relief for post-acquisition discrimination).
cited Cited as authority (rule) Ohio Civil Rights Commission v. Akron Metropolitan Housing Authority
Ohio Ct. App. · 2006 · confidence medium
(C.A.7, 2004), 388 F.3d 327, 330 (hostile living environment based upon *288 religion); Bradley v. Carydale Ents.
discussed Cited as authority (rule) Edwards v. Media Borough Council
E.D. Pa. · 2006 · confidence medium
In holding that harassment by other property owners did not violate the FHA, the Seventh Circuit examined the statute’s legislative history and concluded that “[t]he Fair Housing Act contains no hint either in its language or its legislative history of a concern with anything but access to housing.” Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 329 (7th Cir.2004) (emphasis in original).
examined Cited as authority (rule) Lorraine C. East-Miller v. Lake County Highway Department and Marcus Malczewski (3×) also: Cited "see"
7th Cir. · 2005 · signal: cf. · confidence medium
Cf. Halprin, 388 F.3d at 330 (requiring “a pattern of harassment, invidiously motivated”); see also Walton v. Claybridge Homeowners Assoc., Inc., No. 1:03-CV-69-LJM-WTL, 2004 WL 192106 , at *8 (S.D.Ind.
examined Cited as authority (rule) East-Miller v. Lake County Highway (3×) also: Cited "see"
7th Cir. · 2005 · signal: cf. · confidence medium
Cf. Halprin, 388 F.3d at 330 (requiring “a pattern of harassment, invidiously motivated”); see also Walton v. Claybridge Homeowners Assoc., Inc., No. 1:03-CV-69-LJM-WTL, 2004 WL 192106 , at *8 (S.D.
discussed Cited as authority (rule) Farrar, Nona v. Eldibany, Muhammad
7th Cir. · 2005 · confidence medium
Even assuming that interference with an individual’s enjoyment of a dwelling may support a claim under section 3617 of the Act, see Halprin v. Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 330 (7th Cir.2004) (citing 24 C.F.R. § 100.400 (c)(2)), the interference must constitute more than a simple landlord-tenant dispute; it must constitute a “pattern of harassment, invidiously motivated.” Id.
examined Cited as authority (rule) United States v. Koch (10×) also: Cited "see"
D. Neb. · 2004 · confidence medium
Secondly, the court concluded that the plaintiffs allegations were not severe enough to support a claim under section 3617, because that section only applies to “threatening, intimidating, or extremely violent discriminatory conduct designed to drive an individual out of his home,” such as “cross-burning, firebombing homes or cars, shooting shotguns, physical assaults, or throwing Molotov cocktails.” Id. at 904-04 (citations omitted). 3 On appeal, the Seventh Circuit affirmed the district court’s conclusion that the plaintiffs failed to state a claim under section 3604, stating, “O…
cited Cited "see" Stevens v. HOUSING AUTHORITY OF SOUTH BEND
N.D. Ind. · 2010 · signal: see · confidence high
See Halprin v. Prairie Single Family Homes of Dearborn Park Ass’n, 388 F.3d 327, 329 (7th Cir.2004); see also Jones v. South Bend Hous.
Robyn HALPRIN and Rick Halprin, Plaintiffs-Appellants,
v.
THE PRAIRIE SINGLE FAMILY HOMES OF DEARBORN PARK ASSOCIATION, Et Al., Defendants-Appellees
02-2975.
Court of Appeals for the Seventh Circuit.
Nov 4, 2004.
388 F.3d 327
Thomas Peters (argued), Murphy, Peters & Davis, Chicago, IL, for Plaintiffs-Appellants., Diana M. Kenney (argued), Dvorak & Orum, Chicago, IL, for Defendants-Appel-lees.
Posner, Kanne, Williams.
Cited by 74 opinions  |  Published
POSNER, Circuit Judge.

The district court dismissed this suit under the Fair Housing Act, 42 U.S.C. §§ 3601 eb seq., for failure to state a claim, specifically under sections 3604 and 3617; there are also state law claims, but as is usual the district judge relinquished jurisdiction over them when he dismissed the federal claims before trial. The plaintiffs are a couple who own a home in a suburban subdivision. The principal defendant is the homeowners’ association that manages the subdivision and provides various services to the homeowners. The other defendants, with the exception of a corporation (and its president) that also provides services and is alleged to have acted in cahoots with the association in harassing the plaintiffs, are members of the association; that is, they are the plaintiffs’ neighbors.

The complaint — our only source of facts, because the suit was dismissed for failure to state a claim — alleges the following: One of the plaintiffs is Jewish. The president of the association wrote “H-town property” on a wall of the plaintiffs’ property, “H-town” being short for “Hymie Town,” and he further vandalized the property by damaging trees and plants and cutting down strings of holiday lights. When the plaintiffs posted flyers offering a reward for identifying the vandal, the president destroyed or removed the flyers. To further thwart the plaintiffs’ efforts to investigate the vandalizing of their property, the association destroyed minutes of its board meetings and erased a tape recording of a meeting at which the president had threatened to “make an example” of the plaintiffs. The defendants applied chemicals to the plaintiffs’ yard against the plaintiffs’ wishes and with adverse effects on their health and peace of mind and adopted rules restricting the plaintiffs’ lawful use of their property. The entire campaign of harassment was caused or at least influenced by the religion of the Jewish plaintiff. Of course we do not vouch for any of these allegations, but for purposes of this appeal we must assume that they are true.

A section of the Fair Housing Act makes it unlawful “to coerce, intimidate, threaten, or interfere with any person in the exercise or enjoyment of, or on account of his having exercised or enjoyed, or on account of his having aided or encouraged any other person in the exercise or enjoyment of, any right granted or protected by section 3603, 3604, 3605, or 3606 of this title.” 42 U.S.C. § 3617. The only one of the enumerated sections that is possibly relevant here is section 3604, which makes it unlawful “(a) To refuse to sell or rent after the making of a bona fide offer, or to refuse to negotiate for the sale or rental of, or otherwise make unavailable or deny, a dwelling to any person because of race, color, religion, sex, familial status, or national origin,” or “(b) To discriminate against any person in the terms, conditions, or privileges of sale or rental of a dwelling, or in the provision of services or facilities in connection therewith, because of race, color, religion, sex, familial status, or national origin.” The language indicates concern with activities, such as redlining, that prevent people from acquiring property. Oconomowoc Residential Programs, Inc. v. City of Milwaukee, 300 F.3d[*329] 775 (7th Cir.2002); NAACP v. American Family Mutual Ins. Co., 978 F.2d 287 (7th Cir.1992); Mitchell v. Shane, 350 F.3d 39 (2d Cir.2003); Hamad v. Woodcrest Condominium Ass’n, 328 F.3d 224, 229-31 (6th Cir.2003); San Pedro Hotel Co. v. City of Los Angeles, 159 F.3d 470 (9th Cir.1998); Hogar Agua y Vida en el Desierto, Inc. v. Suarez-Medina, 36 F.3d 177 (1st Cir.1994). Our plaintiffs, however, are complaining not about being prevented from acquiring property but about being harassed by other property owners. So it is difficult to see how they can have been interfered with in the enjoyment of any right conferred on them by section 3604.

As a purely semantic matter the statutory language might be stretched far enough to reach a case of “constructive eviction,” which is one way to describe the present case (more precisely, “attempted constructive eviction”). If you burn down someone’s house you make it “unavailable” to him, and “privileges of sale or rental” might conceivably be thought to include the privilege of inhabiting the premises. Acts of post-sale discrimination have been litigated successfully under the Act in two reported cases, Trafficante v. Metropolitan Life Ins. Co., 409 U.S. 205, 93 S.Ct. 364, 34 L.Ed.2d 415 (1972); Krueger v. Cuomo, 115 F.3d 487 (7th Cir.1997), but in neither was the Act’s applicability to such discrimination discussed — apparently the issue hadn’t been raised. In several other cases the Act has been held to forbid harassment amounting to constructive eviction by analogy to “constructive discharge,” a form of discrimination recognized in Title VII cases. DiCenso v. Cisneros, 96 F.3d 1004, 1008 (7th Cir.1996); Neudecker v. Boisclair Corp., 351 F.3d 361, 364-65 (8th Cir.2003) (per curiam); Honce v. Vigil, 1 F.3d 1085, 1090 (10th Cir.1993). But in none of these cases did the court consider the difference in language between the two statutes. None of the five cases contains a considered holding on the scope of the Fair Housing Act in general or its application to a case like the present one in particular.

Title VII protects the job holder as well as the job applicant, so an employer who resorts to harassment to force an employee to quit is engaged in job discrimination within the meaning of the Act. See, e.g., Herrnreiter v. Chicago Housing Authority, 315 F.3d 742, 744-45 (7th Cir.2002). The Fair Housing Act contains no hint either in its language or its legislative history of a concern with anything but access to housing. Bernard Schwartz, Statutory History of the United States: Civil Rights Part II 1709-17, 1742-51, 1762, 1769 (1970); Hearings before the Subcomm. on Housing & Urban Affairs of the S. Comm. on Banking & Currency on S. 1358, S. 2114, and S. 2280, 90th Cong., 1st Sess. (1967), passim; 114 Cong. Rec. S2274 (daily ed. Feb. 6,1968) (statement of Sen. Mondale). Behind the Act lay the widespread practice of refusing to sell or rent homes in desirable residential areas to members of minority groups. Since the focus was on their exclusion, the problem of how they were treated when they were included, that is, when they were allowed to own or rent homes in such areas, was not at the forefront of congressional thinking. That problem — the problem not of exclusion but of expulsion — would become acute only when the law forced unwanted associations that might provoke efforts at harassment, and so it would tend not to arise until the Act was enacted and enforced. There is nothing to suggest that Congress was trying to solve that future problem, an endeavor that would have required careful drafting in order to make sure that quarrels between neighbors did not become a routine basis for federal litigation.

[*330] Reference to legislative history is criticized when it is used to give a statute a reach that exceeds what its words suggest. Our use here is the opposite; it is to confirm that the words mean what they seem to mean.

So the plaintiffs have no claim under section 3604. And this might seem to doom their claim under section 3617 as well, because that section provides legal protection only against acts that interfere with one or more of the other sections of the Act that are referred to in section 3617, of which the only one even remotely relevant to this case is section 3604.

But this conclusion reckons without a regulation issued by the Department of Housing and Urban Development .that in the name of section 3617 forbids among other things “threatening, intimidating or interfering with persons in their enjoyment of a dwelling because of the race, color, religion, sex, handicap, familial status, or national origin of such persons, or of visitors or associates of such persons.” 24 C.F.R. § 100.400(c)(2). The regulation cuts section 3617 loose from section 3604, contrary to the language of section 3617. Interference with “enjoyment of a dwelling,” forbidden by the regulation, is something that can take place after the dwelling has been acquired, though we know that section 3604 is not addressed to post-acquisition discrimination. The regulation may stray too far from section 3617 (which remember is tied, so far as bears on the issues in this case, to section 3604) to be valid, though Gonzalez v. Lee County Housing Authority, 161 F.3d 1290, 1304-05 and n. 43 (11th Cir.1998), the only appellate decision to address the issue, holds that it is valid. But the defendants have not challenged the regulation’s validity and so its possible invalidity has been forfeited as a ground upon which we might affirm the district court. The defendants quote the regulation, but only to observe, quite mistakenly, that it “simply reiterates the language of section 3617.” The entire point is that it does not. If it did, the defendants would be home free.

The remaining question is whether the conduct alleged in the complaint amounts to “threatening, intimidating or interfering” within the meaning of the statute and the regulation. The defendants argue that it does not, because it is far less ominous, frightening, or hurtful than burning a cross in a neighbor’s front yard or assaulting the neighbor physically. But that cannot be the test. There are other, less violent but still effective, methods by which a person can be driven from his home and thus “interfered” with in his enjoyment of it. See, e.g., Krueger v. Cuomo, supra, 115 F.3d at 490-91 (sexual harassment); Regional Economic Community Action Program, Inc. v. City of Middletown, 294 F.3d 35, 43-44 (2d Cir.2002) (economic pressure); Walker v. City of Lakewood, 272 F.3d 1114, 1126-31 (9th Cir.2001) (same). Of course, to repeat an earlier point, we do not want, and we do not think Congress wanted, to convert every quarrel among neighbors in which a racial or religious slur is hurled into a federal case. But what is alleged in this case (as in the factually similar case of Ohana v. 180 Prospect Place Realty Corp., 996 F.Supp. 238, 239 (E.D.N.Y.1998)) is a pattern of harassment, invidiously motivated, and, because backed by the homeowners’ association to which the plaintiffs belong, a matter of the neighbors’ ganging up on them. We are far from a simple quarrel between two neighbors or the isolated act of harassment committed by the landlord in DiCenso v. Cisneros, supra, 96 F.3d at 1006.

The case is affirmed in part, but for the reasons just explained it is reversed with regard to the section 3617 charge, which[*331] we direct the district court to reinstate along with the state law claims, which the court dismissed only because it mistakenly believed that the complaint failed to state a federal claim.

AFFIRMED IN PART, REVERSED IN PART, and Remanded.