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DeYoung et al. v. National Association of Realtors et al.
Filed
January 2025
Jurisdiction
Middle District of Louisiana (Baton Rouge)
Plaintiff Firm
Plaintiffs' Counsel (Middle District of Louisiana)
Next Milestone
Second amended complaint filed; NAR and Louisiana co-defendants expected to move to dismiss; ruling expected summer 2026
Brokers Carla DeYoung and Carlos Alvarez, along with agents Tammy Jo Williams and Darlene Currie, allege that NAR, the Greater Baton Rouge Association of Realtors (GBRAR), the New Orleans Metropolitan Association of Realtors (NOMAR), ROAM MLS, and other Louisiana-based defendants engaged in anticompetitive and exclusionary practices by conditioning access to MLS data and MLS-related platforms on compulsory membership in local, state, and national Realtor associations. The plaintiffs — who include both brokers and agents — argue this bundled membership requirement constitutes an illegal tying arrangement that forecloses competition and forces practitioners to pay dues to organizations they may not wish to join in order to access the MLS tools essential to their business.
Original federal antitrust and Fair Housing Act claims were dismissed without prejudice in late March 2026 based on the Magistrate Judge's report and recommendations. In late April 2026, the federal court granted plaintiffs' motion to file a second amended complaint, giving them another opportunity to replead the dismissed federal claims. NAR stated it 'supports pro-competitive, pro-consumer local broker marketplaces' and that 'each local MLS sets their own requirements for determining access to the platform.' The case is one of several parallel MLS membership challenges filed across the country in 2024–2025, suggesting a coordinated litigation strategy targeting the bundled membership model.
DeYoung Filed
January 2025Complaint filed in Middle District of Louisiana by brokers Carla DeYoung and Carlos Alvarez, along with agents Tammy Jo Williams and Darlene Currie, alleging anticompetitive MLS access restrictions tied to compulsory Realtor association membership
Briefing on Motion to Dismiss
2025–2026NAR and Louisiana co-defendants (GBRAR, NOMAR, ROAM MLS) file motion to dismiss; parties brief the issues
Federal Claims Dismissed Without Prejudice
Late March 2026Court dismisses federal antitrust and Fair Housing Act claims without prejudice, based on report and recommendations of Magistrate Judge; plaintiffs given opportunity to amend
Second Amended Complaint Granted
Late April 2026Federal court grants plaintiffs' motion to file a second amended complaint, allowing them to replead dismissed federal claims alleging conditioning of MLS access on compulsory Realtor association membership
Second Amended Complaint Filed
May 2026Plaintiffs file second amended complaint repleading federal antitrust claims; NAR and co-defendants expected to move to dismiss again
Category
MLS Rule ChallengesNWMLS rules block Compass's three-phased marketing strategy
Category
MLS Rule ChallengesVarious class-action lawsuits filed against regional MLSs regarding commission structures. This category includes Nosalek v. MLS PIN (Massachusetts), Compass v. Northwest MLS (Washington), and MLS defendants in Moehrl case.
Category
MLS Rule ChallengesCompass alleges NWMLS, a non-NAR-affiliated MLS serving the Seattle/Pacific Northwest market, operates as a monopolist by fining agents $5,000 for publicly marketing listings outside NWMLS before sharing them on the MLS. Compass argues this rule restricts seller-directed marketing, harms competition, and benefits incumbent brokerages that control NWMLS.
This case is part of a coordinated wave of lawsuits challenging NAR's mandatory Realtor association membership requirements for MLS access. Each takes a different legal angle — together they form the most comprehensive attack on the bundled membership model since the DOJ's 2020 investigation.
Deep Dive: Comparing the Three MLS Membership Lawsuits
How DeYoung, Hardy, and Zea differ in legal theory, geography, and odds of success
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