Further, the ALJ held that because Ross had no legitimate,
non-discriminatory business reason for this practice, he violated the Fair Housing Act's prohibition on sex discrimination.
Regarding indirect discrimination: (1) the plaintiff must show a prima facie case of discrimination; (2) the defendant may rebut the claim with proof of legitimate,
non-discriminatory business reasons for his actions; and (3) a plaintiff may show that the reasons were pretextual.