A tenant has accused her former apartment management company and their legal counsel of retaliating against her after she reported a dog attack and raised safety concerns related to her disability and that of her minor child. The complaint was filed by LaKeshia LaFleur in the United States District Court for the Southern District of Texas on March 20, 2026, naming Momentum Deerbrook DE, LLC doing business as The Henry at Deerbrook Apartments, Momentum Multifamily, LLC, Asset Living, attorney Robert E. Bone, Esq., and unnamed defendants.
According to the filing, LaFleur brings claims under the Fair Housing Act as well as related federal and Texas law. She alleges discrimination, retaliation, interference with housing rights, constructive eviction, harassment, coercion, and pretextual enforcement actions following her protected activity. The plaintiff states that both she and her eleven-year-old daughter are members of protected classes due to disabilities—LaFleur herself has a mental health disability while her daughter has Attention Deficit Hyperactivity Disorder (ADHD).
The dispute began after an incident on October 16, 2024 when LaFleur was attacked by an undisclosed dog on the apartment property. She reported the incident to BARC Animal Control which generated an official report. Management informed LaFleur that the dog involved was not listed on any lease nor disclosed to them; documentation later submitted by another tenant claiming the animal was for health reasons was described as fraudulent in the complaint.
LaFleur claims she repeatedly requested intervention from management to enforce lease terms for safety but alleges no comparable action was taken against the tenant responsible for the dog. Instead, she asserts that enforcement actions were escalated against her. The complaint states that objective evidence supporting LaFleur’s account—including animal control reports and video surveillance—was ignored while unverified allegations against her were accepted without investigation.
The lawsuit details further contradictions in defendants’ narrative. For example, while defendants claimed tenants feared for their safety due to LaFleur’s alleged aggressiveness, those same tenants reportedly continued routine contact with her. As quoted in court documents: “The notice claims the tenants feared for their safety. However, those same tenants routinely walked past my unit… Their conduct contradicts the allegation of fear.”
Attorney Robert E. Bone is named personally in several allegations within the suit. According to LaFleur’s filing, Bone authored sworn pleadings escalating eviction notices and personally delivered court documents to her residence despite asserting in court filings that tenants and staff feared for their safety around her. The plaintiff argues these actions demonstrate internal contradictions undermining defendants’ stated reasons for eviction.
LaFleur also accuses Bone of abusing his authority as an attorney by using legal proceedings not simply as neutral remedies but as tools of intimidation following complaints made to housing authorities and other agencies. She contends that motions filed during prior eviction proceedings sought to prevent courts from hearing evidence related to discrimination or retaliation.
In addition to issues surrounding herself directly, LaFleur describes an incident where defendants attempted to remove a motorcycle belonging to her child after threats of eviction began—a move she characterizes as selective harassment intended to intimidate.
The complaint asserts that these collective actions resulted in constructive eviction by creating a hostile environment through repeated threats and escalating notices. It also claims procedural tactics limited LaFleur’s ability to present evidence supporting civil-rights violations since Texas eviction courts only determine possession rather than underlying discrimination claims.
As part of her case under multiple sections of the Fair Housing Act—including retaliation (42 U.S.C § 3617), discriminatory terms based on disability or familial status (42 U.S.C §§ 3604(f)(2), 3604(b)), failure to accommodate (42 U.S.C § 3604(f)(3)(B)), and state law constructive eviction—LaFleur seeks compensatory damages for emotional distress and financial hardship allegedly caused by defendants’ conduct.
She further requests punitive damages intended to deter similar conduct in future cases; declaratory relief stating defendants violated federal law; injunctive relief ordering cessation of discriminatory practices; reimbursement for court costs; any additional relief deemed just by the court; and a jury trial on all triable issues.
The filing notes that LaFleur is representing herself pro se in this matter. No defense attorneys are listed in this initial complaint document. The case is identified as Case 4:26-cv-02261.
Source: 426cv02261_Lakeshia_Lafleur_v_Momentum_Deerbrook_Complaint_Southern_District_of_Texas.pdf
