Improper Revocation of a Disabled Tenant's Housing Subsidy by the Augusta (Maine) Housing Authority

C O N F I D E N T I A L

Improper Revocation of a Disabled Tenant’s Section 8 Housing Subsidy by the Augusta

(Maine) Housing Authority

Prepared by: Eli A. Blackhouse (formerly Benjamin Turner)For: Attorney Daniel BuckFinish date: June 15, 2007

Signed:

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Last printed 6/15/2007 4:27 PM


Part I: NarrativeThe matter involves the improper termination of Benjamin

Turner’s Section 8 federal housing subsidy by the Augusta Housing Authority (“AHA”). The authority administers the Federal Section 8 housing subsidy program for residents of central Maine towns in their jurisdiction.

As their premises at 33 Union Street are both generally inaccessible to the disabled population and inaccessible to the complainant given specific features of his disability, Mr. Turner requested an alternative to having to enter the AHA offices to sign housing-related paperwork. The AHA should have readily granted this reasonable accommodation request by offering to meet with Mr. Turner at an off-site location or by mailing any necessary subsidy-related paperwork to his residence rather than requiring him to sign such paperwork on-site.

However, rather than accommodate Mr. Turner’s disability, the AHA predicated his right to participate in his Section 8 housing subsidy on fulfillment of exclusionary medical requirements. Such conditions compromised federal law mandating an easily obtained reasonable accommodation and interfered with Mr. Turner’s disability rights, as specific features of his disability prevents him from being able to interact with doctors.

After he made the initial reasonable accommodation request, the AHA began to write letters and place telephone calls to Mr. Turner which contained excessive medical directives and included mischaracterizations of his effort to avoid such medical harassment as a failure “to cooperate.” All of these conditions served to agitate his relationship with his landlord, as it rendered the continued provision of AHA subsidy disbursements to Mr. L as a tenuous arrangement the authority would readily terminate if Mr. Turner declined to forego his right to accessible participation.

The AHA’s refusal to mail him the required annual Section 8 recertification forms as a reasonable accommodation resulted in




the revocation of his housing subsidy, effective August 1, 2005, as Mr. Turner had not been able to sign standard recertification forms without the accommodation. Upon receiving termination notification, he immediately filed a grievance, at which point Hearing Officer Catherine Austin further violated his rights by repeatedly attempting to have him submit to a medical examination as a condition of conducting the hearing at his home.

When his disability prevented him from fulfilling these deterring and non- ADA-compliant medical requirements, Ms. Austin stated that to continue to receive his subsidy, he would have to submit to an at-home meeting, further specifying that the meeting would not occur as fulfillment of his request for a reasonable accommodation. This requirement both violated Mr. Turner’s right to have his disability recognized and accommodated – on that occasion and on future occasions – and lent an intimidating timbre to the mandatory home-meeting that would ensue in place of an acknowledged accommodation.

Once at his home, Hearing Officer Catherine Austin refused to address Mr. Turner’s complaints regarding accessibility, the AHA’s pattern of illegally requiring medical examinations, and the revocation of his subsidy as a consequence of his inability to participate in such examinations. After the meeting, despite having promised to continue to pay his Section 8 subsidy, the AHA discontinued doing so, abruptly stopping payments to his landlord in October, 2005. As the AHA terminated his benefit without notifying him in advance, he did not discover that the AHA had stopped payments to his landlord until Mr. L notified him that the authority had not mailed their portion of the rent to the landlord’s home. The AHA’s refusal to provide definitive written notification that they were proceeding with subsidy termination violated federal regulationsi and also caused the landlord to attempt to evict Mr. Turner (on October 31, 2005, as a direct result of the missing AHA payment).

Shortly after discovering that the AHA had stopped payments to his landlord, Mr. Turner detailed his complaint in a written letter and mailed it to the Boston HUD Office, also requesting that the regional branch compel the AHA to reinstate




his subsidy. Several weeks later, the written response he received offered only a hollow reiteration of the AHA’s misrepresentation of events and included the statement that the AHA had terminated his benefits because Mr. Turner had failed to fulfill medical requirements, which the Boston HUD Office faultily and discriminatorily described as having been among standard tenant obligations. The letter ignored wholesale his central assertion that the AHA had terminated his housing subsidy during the course of deterring his participation by deliberately exploiting both his disability and the reasonable accommodation process.

He abandoned additional efforts to re-establish the subsidy when he realized that both the AHA and the Boston HUD Office had misrepresented several key elements regarding his complaint.




PART II: Analysis of AHA Malfeasance

Section 1: Medical Harassment Was Used to Block Tenant’s Administrative Participation

The AHA violated laws relative to reasonable accommodation during two separate periods of time.

The first violation occurred when they failed to provide a definitive response to Mr. Turner’s initial request for reasonable accommodation, which he had made directly to the AHA’s director, Victoria Watkins. The AHA’s failure to act on his initial request led to the revocation of the subsidy, as, without the accommodation, he could not fulfill standard obligations relative to re-certification.

The AHA additionally violated his disability rights after Mr. Turner filed the grievance regarding subsidy termination, at which point Ms. Austin attempted to require Mr. Turner to submit to a medical examination as a condition of fulfilling his request to have the termination-related hearing conducted offsite (and not in the inaccessible AHA offices).

Both the subsidy termination and the hearing relative to the same would have been avoided had the AHA simply mailed the relevant re-certification paperwork to Mr. Turner when he requested that they do so. Providing such an accommodation on both occasions was their responsibility according to HUD anti-discrimination and accessibility rulesii and the Americans with Disabilities Act.




Despite their repeated claims to the contrary, no regulation precluded the AHA from accommodating him offsite in the absence of a medical examination, and his requested accommodation not to have to enter the premises should have been readily granted without a specific medical dispensation -- on both occasions -- for the following seven (7) reasons:

1. The nature of Mr. Turner’s disability prevented him from interacting with doctors. Their attempts to require him to interact with a physician did not take into account that his disability prevented him from doing so. Since his disability-related symptoms would have been exacerbated by a medical examination, he could not interact with doctors for the purpose of evaluating his disability.

Mr. Turner’s disability is so advanced that the Social Security Administration eventually decided to continue to pay his SSDI benefit despite his inability to participate in a medical review, a conclusion that presumably acknowledged that medical testing had been refused by Mr. Turner for good cause.

In light of the SSA’s decision, the AHA’s refusal to accommodate Mr. Turner if he did not participate in a medical examination meant that during the time in which he attempted to have his disability accommodated by the AHA, the federal government was simultaneously acknowledging that Mr. Turner’s disability prevented him from meeting with doctors (through the SSA) while requiring him to meet with doctors to continue to receive his disabled housing benefit (through the AHA).

2. The AHA already possessed sufficient evidence of the need to accommodate Mr. Turner’s disability. Mr. Turner had already provided credible attestation regarding his disability during the initial request he made with Ms. Watkins. Additionally, his known status as a disabled SSDI recipient should have constituted adequate proof of his right to reasonable accommodation, as the AHA was aware




that the government had already declared him fully disabled under federal guidelines.

3. Requiring an unnecessary medical examination in advance of providing accommodation denied the complainant the opportunity to attest to his disability-related needs. That Mr. Turner’s disability was considered non-existent without third-party verification seriously undermined Mr. Turner’s right to be considered the best describer of his disability-related accommodation needs.iii

The AHA’s requirement of a medical examination even given the presence of evidence specifically listed as acceptable in HUD’s reasonable accommodation policy (e.g., that he received SSDI) discriminatorily represented that disabled individuals are prone to misrepresent or not understand their disability-related needs.

4. The total effect of their procedural and administrative efforts prevented Mr. Turner’s participation in his housing subsidy. When considered collectively, both the AHA’s specific procedural infractions and their repeated attempts to compel unauthorized medical examinations violated the overarching federal stricture directing public housing authorities not to “defeat or substantially impair the accomplishment of the objectives of the recipient’s federally assisted program.”iv

As their combined actions precluded his participation, they were required to alter these actions and policies to accommodate him. By continuing their excessive demands and presenting local protocols as immutable requirements bearing more stringency than federal law, the AHA made the housing process adversarial instead of focusing – per regulatory directive – on how best to accommodate Mr. Turner.

5. The AHA was obligated to accommodate him offsite in the first place because 33 Union Street is not generally accessible to the disabled. The AHA should not have required Mr. Turner to submit written applications (in the




form of medical review forms) to be accommodated at an offsite location as they had the burden, as a participating PHA, to provide a meeting area accessible to disabled individuals in the first place.v




6. His right to the off-site accommodation should not have been represented as contingent upon their approval. The AHA’s demand that Mr. Turner submit to unnecessary medical examinations suggested their belief that local policies are not subordinate to the ADAvi and represented Mr. Turner’s disability rights as ultimately contingent upon AHA approval.

Mr. Turner’s right to the requested reasonable accommodation was an inalienable federal right: it did not require a medical examination or additional application for rights. Under no circumstances should the AHA have represented that his disability rights required physician approval, third-party verification, or “approval by the housing authority” (as stated in their written correspondence to him during this time). His federal right to disability-related accommodations prevailed in the absence of completed local forms or medical examination.vii

7. Their tacit intention was to discourage Mr. Turner from continuing to exercise his disability rights. Their focus should have been on successful administration of the housing benefit for Mr. Turner as a disabled tenantviii and not on locating reasons to exclude him. He had no obligation to fulfill any requirements – medical or otherwise – ostensibly to authorize an offsite meeting that was, in fact, illegally intended to discourage him from exercising his disability rights.

A required alternative disability accommodation was never offered

Even had the AHA been unable to accommodate his initial request, both the Americans with Disabilities Act and HUD regulations would still have required them to “take any other action” to ensure that “to the maximum extent possible” he would receive the “benefits and services” of the HUD-assisted program. ix

A first-attempt failure for the two parties to find a suitable disability-related accommodation should not have been construed as cause to discontinue the subsidy. On the contrary, if the AHA




had not been able to fulfill Mr. Turner’s reasonable accommodation request (and this was not the case), said regulations would have constrained them to offer an alternative accommodation, at which point Mr. Turner should have had the opportunity to assess whether the alternative accommodation offered would have suitably accommodated his disability in lieu of the one he initially requested. x

The AHA made no such additional mandatory accommodation efforts.




Section 2: The AHA Committed Termination- and Hearing-Related Violations

As described in the first section of this document, by imposing a prohibitive medical review as a condition of mailing him necessary paperwork or holding an offsite meeting, the AHA blocked him from fulfilling standard obligations. They then used the unfulfilled standard obligation to justify revoking his subsidy. The revocation caused Mr. Turner to file a grievance, at which point the AHA renewed its effort to deter Mr. Turner’s participation by requiring a medical examination as a condition of holding the hearing relative to the grievance in an accessible location.

Subsection A: The AHA improperly converted the complainant’s right to reasonable accommodation and fair participation into a deterring administrative process

Ms. Austin’s repeated directives to the contrary of federal law and HUD regulations promoted Mr. Turner’s belief that the AHA would invent administrative loopholes to remove him from the program if they chose to do so (e.g., if he continued to complain about inaccessibility). Indeed, they had already exploited his disability when they blocked him from fulfilling standard obligations by administering a reasonable accommodation process that was itself inaccessible.

On numerous occasions, AHA staff permitted or created conditions that deterred his participation despite their obligation to make a rigorous, good-faith effort to include him. To wit:




In refusing to mail recertification paperwork, the AHA violated HUD policy

Their refusal to adhere to federal disability accommodation law was apparent in a letter from Catherine Austin dated 7/22/05, in which she stated that mailing paperwork for him to sign at home “is not our policy,” in addition to stating that mailing the papers would require a medical examination. This refusal to waive local policy to accommodate Mr. Turner’s disability directly violated federal rules requiring the AHA to provide alternative forms of communication to accommodate disabled tenants.xi i 24 CFR § 982.55 (e) (6). “Issuance of decision. The person who conducts the hearing must issue a written decision, stating briefly the reasons for the decision. Factual determinations relating to the individual circumstances of the family shall be based on a preponderance of the evidence presented at the hearing. A copy of the hearing decision shall be furnished promptly to the family.”

ii Notice PIH 2006-13 (HA)(II)(F)(1). The entire paragraph is as follows: “Application Process. PHAs must ensure that all employees who are involved in the application process understand how to conduct tenant selection and screening without discriminating on the basis of any protected class, in particular applicants with disabilities. All application offices must be accessible. The PHA must provide accessible materials for persons with sight and hearing impairments and otherwise provide effective communication, upon request. Also see 24 C.F.R § 8.6. “A PHA must make special arrangements to take the application of persons who are unable to come to the PHA’s offices because of a disability. At the initial point of contact with each applicant, the PHA must inform all applicants of alternative forms of communication.” Also see Notice PIH 2002-01 (HA)(II)(C)(1) (similar phraseology).

iii HUD/DOJ, “Joint Statement,” § 7. “…Providers should be aware that persons with disabilities typically have the most accurate knowledge about the functional limitations imposed by their disabilities.”

iv 24 CFR 8 § 4(b)(4)(ii). A similar instruction appears in Notice PIH 2002-01 (HA) (I)(D)(3): “A public entity shall operate each service, program or activity so that when viewed in its entirety, each service, program or activity is readily accessible to and usable by individuals with disabilities.” (Emphasis mine) (28 CFR 35.150 cited) HUD reiterates the instruction in Notice PIH 2006-13 (HA)(I)(B)(10). “For existing non-housing facilities, PHAs shall operate each program or activity receiving federal financial assistance so that the program or activity, when viewed in its entirety, is readily accessible to and usable by individuals with disabilities.”




Inquiries into Mr. Turner’s disability were only made to deter him from fulfilling standard obligations

Communications between the AHA and Mr. Turner failed in part because the AHA had not sufficiently or fairly ascertained the extent and nature of Mr. Turner’s disability for the purpose of assuring its effective accommodation. Rather, inquiries into his medical history only served to exclude him from fair participation.

v Notice PIH 2002-01 (HA) (II)(C)(1). “All application offices must be accessible… A PHA must make special arrangements to take the application of persons who are unable to come to the PHA because of a disability.” Also see 24 CFR 8 § 5(i-ii). “In determining the site or location of a federally assisted facility, an applicant for assistance or a recipient may not make selections the purpose or effect of which would (i) exclude qualified individuals with handicaps from, deny them the benefits of, or otherwise subject them to discrimination…or (ii) defeat or substantially impair the accomplishment of the objectives of the program with respect to…individuals with handicaps.”

vi See The Fair Housing Act of 1988/24 CFR 100, “shall follow the more stringent requirements” Also see 24 CFR 8 § 4(e): “The obligation to comply (with federal regulations) is not obviated or alleviated by any State or local law or other requirement that, based on handicap, imposes inconsistent or contradictory prohibitions or limits upon the eligibility of qualified individuals with handicaps to receive service…”

vii 24 CFR § 982.54. “The (local PHA’s) administrative plan must be in accordance with HUD regulations and requirements.” The AHA’s local administrative plan did not nullify their obligation to act within the parameters of other federal laws (such as the ADA).

viii Notice PIH 2002-01 (HA) (II)(C)(5). “The focus should be on finding a reasonable accommodation that will permit the applicant to comply with the essential obligations of tenancy.”

ix 24 CFR § 8.6 (c). See also Notice PIH 2002-01 (HA), which states that the PHA is required to provide “any other” required accommodation.

x See HUD/DOJ, “Joint Statement,” § 7. “…An individual is not obligated to accept an alternative accommodation suggested by the provider if (he) believes it will not meet (his) needs and (his) preferred accommodation is reasonable.”




The AHA required Mr. Turner to make duplicate requests for reasonable accommodation

In responding to his request that the termination-related hearing be held at his home rather than at the inaccessible AHA premises, the AHA stated that Mr. Turner could request a reasonable accommodation as a person with disabilities, yet he had already requested an accommodation with respect to mandatory on-site meetings during his initial discussion of the matter with Ms. Watkins.

The AHA applied improper format restrictions relative to Mr. Turner’s reasonable accommodation requests

The AHA also attempted to forestall his subsidy-related participation by improperly applying format requirements of their own invention – once again, in violation of federal (ADA) accommodation laws. Not only did Ms. Austin ignore the extant reasonable accommodation request Mr. Turner had made to Ms. Watkins, she attempted to constrain Mr. Turner to adhere to a specific paperwork format upon requiring him to make a second request for reasonable accommodation, stating that the AHA “(could not) waive (the) action” of requiring Mr. Turner to file the request in written form. This restriction of reasonable accommodation format both deterred his participation and directly violated the Americans with Disabilities Act and HUD policy, both of which specify that reasonable accommodation requests must not be refused by the participating housing authority simply because the disabled requester does not use a format preferred by the administering agency.xii Ms. Austin had no legal authority to insist that Mr. Turner make his request for reasonable accommodation in written form.

xi Notice PIH 2006-13 (HA) (II)(F)(2).

xii HUD/DOJ, “Joint Statement,” § 12. “Housing providers must give appropriate consideration to reasonable accommodation requests even if the requester makes the request orally or does not use the provider’s preferred forms or procedures for making such requests.”




The hearing officer required a home meeting to occur, but not in fulfillment of Mr. Turner’s request for reasonable accommodation

While the AHA should not have required a medical examination as a condition of accommodating him in the first place (for the seven [7] specific reasons listed above), after representing their decision-making regarding offsite accommodation as part of a reasonable accommodation process, they then proceeded to substitute what should have been a definitive response to his request (i.e., a formal approval or denial of the specific accommodation requested) with a one-time meeting. By refusing to offer an accommodation but insisting upon a home meeting that would occur exterior to the reasonable accommodation process, they implicitly suggested that they could – upon any future attempts by Mr. Turner to have his disability accommodated via an offsite meeting – either refuse to provide accommodation or re-initiate excessive medical requirements in advance of doing so. In fact, federal disability accommodation law required them to accommodate Mr. Turner’s disability on that and every subsequent occasion on which they required him to sign paperwork.

Both the content and the nature of the meeting suggested that the AHA would never recognize or accommodate his disability.

The hearing officer violated ex parte communication rules

During the home meeting, her efforts had clearly been informed by communications in which she had obviously engaged with Ms. Watkins or other AHA parties. These communications had either biased her handling of Mr. Turner’s case or was otherwise in-line with the pre-existing agenda of requiring Mr. Turner to forego his disability rights. The advancement of such an agenda violated her obligations regarding ex parte communications, which constrained her to act as an impartial adjudicator regarding the revocation of Mr. Turner’s subsidy.xiii In positioning herself as a direct emissary of the AHA, Ms. Austin subordinated what should have been unbiased decision-making to




the AHA’s ongoing agenda of refusing to accommodate his disability.

The Boston HUD Office misrepresented the cause of subsidy termination

In their response to his written complaint, the Boston HUD office did not address the AHA’s accessibility-related failures cited by the plaintiff, an omission which demonstrated their monumentally deficient understanding of HUD policy. Additionally, their letter’s attribution of the subsidy revocation to Mr. Turner’s having been “unwilling” to enter the inaccessible AHA premises and “refusing” to participate in exclusionary and rights-violating paperwork resembled the same pre-emptive and discriminatory postures adopted by the AHA.

In their description of what had occurred, the Boston HUD Office fused disability-related procedures to standard ones to create the appearance that the termination had been justified, stating that Mr. Turner’s subsidy had been revoked because he had not provided medical documentation of his disability. Contrary to this outrageous remark – which suggested that the Boston HUD Office believed that disabled individuals were required to participate in medical examinations to maintain their tenancies – Mr. Turner had failed to fulfill standard obligations on several occasions only because the AHA had illegally blocked him from doing so by refusing to grant reasonable accommodations.

Of course, the reasonable accommodation process should not have been viewed as includable among standard tenant obligations in any event, given that such an inclusion would have illegally required Mr. Turner to fulfill more standard obligations than non-disabled tenants.

xiii 24 CFR § 982.555 (e)(4). This regulation specifies that termination-related hearings must be conducted by someone other than a “person who made or approved the decision [to revoke the subsidy] under review or a subordinate of this person.”




Subsection B:Other violations occurring during this time

The AHA made unethical evaluations of and inquiries into Mr. Turner’s medical history

In her communications with Mr. Turner, Ms. Austin discriminatorily described Mr. Turner’s disability-related inability to enter the AHA premises as a volitional shortcoming (i.e., a character flaw) rather than a feature of a disabling condition readily and credibly evidenced by his status as an SSDI recipient. She also requested disability-related medical information that included inquiries into both the severity and nature of the disability. Such excessive inquiring violated HUD policy and discriminated against him as a disabled AHA tenant.xiv

Ms. Austin’s attempts to gather and evaluate Mr. Turner’s personal medical information included the discriminatory description of Mr. Turner’s disability-related inability to enter the location as “reticence.” This improper application of her personal, non-professional opinionxv was, at its essence, glibly dismissive of both Mr. Turner’s inability to enter the premises and his right to be considered the best representative of his disability-related needs. In fact, she did not possess the right, need, or medical training to comment on the nature or severity of his disability, and her attempts to acquire details regarding Mr. Turner’s disability generally violated her regulatory obligation not to probe unnecessarily into Mr. Turner’s personal health history.xvi

The AHA’s actions violated their contractual obligations to both Mr. Turner and his landlord

By revoking the subsidy, the AHA violated their contractual obligation to pay Mr. Turner’s subsidized rent

xiv Notice PIH 2006-13 (HA) (I)(E)(1). “Illegal Inquiries (24 CFR § 100.202) – The Fair Housing Act makes it unlawful for a housing provider to…ask about the nature or severity of a disability of (an applicant for a dwelling).”




continuously throughout his tenancy, thereby requiring Mr. Turner to fulfill elements of the multi-party lease that were – according to the terms of such a lease – theirs alone to fulfill. While federal regulations state that the family “is not responsible for (paying the) HAP [housing authority payment] contract between the owner and the PHA”xvii and that “the owner may not terminate the tenancy of the family for non-payment of the PHA,”xviii the AHA’s failure to pay the October, 2005 rent required Mr. Turner to pay full rent in addition to the back rent unpaid by the AHA. Their compelling him to pay the rental deficit created the impression that he was now a party to the AHA/landlord covenant. This was not the case.xix On the contrary, the AHA’s failure to pay the HAP violated their contractual agreement with the landlords.

Additionally, in converting their contractual obligation to pay Mr. Turner’s Section 8 subsidy into a private lease between Mr. L and Mr. Turner, the AHA forced Mr. Turner into a lease that featured neither the disability-related assurances nor standard protections required by HUD.xx

xv HUD/DOJ, “Joint Section,” (II)(E)(3). “PHAs may not make judgments as to an individual’s ability to perform a task based on a person’s disability.”

xvi Notice PIH 2002-01 (HA) (E)(3). “PHA’s may not make judgments as to an individual’s ability to perform a task based on a person’s disability.” Also see Notice PIH 2002-01 (II) (C)(3). “A PHA may not require applicants to provide access to confidential medical records in order to verify a disability nor may a PHA require specific details as to the disability.”

xvii 24 CFR 982.310 (b)(1). Also see 24 CFR 982.451 (b)(4)(iii). “The family is not responsible for payment of the portion of rent to owner covered by the housing assistance payment under the HAP contract between the owner and the PHA.”

xviii 24 CFR 982.310 (b)(2). “The PHA failure to pay the housing assistance payment to the owner is not a violation of the lease between the tenant and the owner. During the term of the lease the owner may not terminate the tenancy of the family for non-payment of the PHA housing assistance payment.”

xix 24 CFR 982.456 (b)(1). “The family is not a party to or third party beneficiary of the HAP contract.”




Subsidy termination caused a rent-to-income ratio that prevented him from moving to a suitable dwelling

The revocation of the benefit (October, 2005) required him to allocate a large percentage of his monthly SSDI payment (unadjusted) to rent. This requirement for him to pay rent disproportionate to his adjusted income violated the federal requirement that the family share of rent “not exceed 40 percent of the family’s monthly adjusted income.”xxi The precipitous subsidy termination also violated HUD regulations requiring the AHA to assess the impact funding termination would have on Mr. Turner as a disabled tenantxxii as well as his right to a voucher extension that would have helped him navigate the “special problems of locating accessible units.”xxiii

In wrongfully terminating his voucher without prior notice, the AHA disallowed his transition into suitable replacement housing.

xx Notice PIH 2006-13 (HA) (I)(B)(9)(1)(IV). “In order to ensure that participating owners do not discriminate in the recipient’s federally assisted program, a recipient shall enter into a HUD-approved contract with participating owners, which contract shall include necessary assurances of non-discrimination.” Also see 24 CFR 982.452 (b)(3): “(The owner is responsible for) complying with equal opportunity requirements.” Other standard (non- disability-related) oversight also vanished when the AHA improperly terminated their commitment to pay Mr. Turner’s subsidy (e.g., the PHA was no longer present to notify the landlords of defects in the apartment, as required by 24 CFR § 982.405, so the AHA deprived Mr. Turner of standard tenant-landlord advocacy as well).

xxi 24 CFR § 982.305 (a)(5).

xxii 24 CFR 982.552 (c)(2)(iii). “If the family includes a person with disabilities, the PHA decision concerning such action is subject to consideration of reasonable accommodation in accordance with part 8 of this title.”

xxiii Notice PIH 2002-01 (HA)(I)(B)(7).



Improper Revocation of a Disabled Tenant's Housing Subsidy by the Augusta (Maine) Housing Authority

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