Skip to main content
DRAFT FOR ATTORNEY REVIEW — NOT FINAL

§ 1437d

Citation
§ 1437d
Parent Document
Eunice Samuels, Lorraine Warren v. District of Columbia, 770 F.2d 184 (1985)
Effective Date
1985-08-06

Other Sections in This Document (234)

Full Text

509 chars
District’s Brief at 19. Under the District’s reading of the grievance procedure requirement, however, a PHA’s "failure" to lower rent under section 1437a when a tenant's income decreases is not subject to an administrative hearing because the PHA has not "proposed" to take any "action." We do not believe that Congress could have intended such a surprising application of the grievance procedure requirement without some express indication that PHA inaction is excluded from the scope of section 1437d(k). 14