This Summary will discuss the standard that the Sixth, Ninth, and Tenth Circuits have adopted, as well as the opposing viewpoint of the Eighth Circuit. In discussing the various standards that courts of appeals have adopted, this Summary will demonstrate that the standard currently employed by the Eighth Circuit fails to adequately prevent and protect citizens from housing discrimination, as intended by the Fair Housing Act. The Summary will ultimately conclude that the Sixth, Ninth, and Tenth Circuits have applied the appropriate standard, and that the Eigth Circuit needs to join those Circuits in applying a standard that encourages those wronged by housing discrimination to challenge unfair housing policies and practices.

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