Open Cmtys. Alliance v. Carson, 286 F. Supp. 3d 148 (2017)

Citation: Open Cmtys. Alliance v. Carson, 286 F. Supp. 3d 148 (2017)
Parent Document: Open Cmtys. Alliance v. Carson, 286 F. Supp. 3d 148 (2017)
Jurisdiction: United States (federal)
Effective Date: 2017-12-23
Original Source: https://www.courtlistener.com/opinion/7328080/open-cmtys-alliance-v-carson/ ↗

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On August 10, 2017, HUD issued a memorandum delaying SAFMR designations for 23 of the 24 metropolitan areas subject to the Rule (excluding Dallas), requiring PHAs in affected areas to implement the Rule in 2020 rather than in 2018. Defs.' Opp'n, Ex. 2, Suspension of Small Area Fair Market Rent (FMR) Designations ("Suspension Mem.") at 2, ECF No. 24-5. The Suspension Memo expressly noted, however, that "any PHA operating in the covered metropolitan areas" could still "voluntarily implement[ ] the use of Small Area FMRs prior to ... 2019," and that PHAs in the Dallas metropolitan area would continue to implement SAFMRs pursuant to the settlement agreement. Id. at 1, 3. On August 11, 2017, HUD sent over 200 affected PHAs a letter informing those PHAs that their metropolitan areas' mandatory SAFMR designations were suspended until 2020. Defs.' Opp'n, Ex. 3, Letter from Dominique Blom, Gen. Deputy Assistant Sec'y for Public & Indian Housing, HUD, to PHA Exec. Dirs. ("Letter to PHAs") (Aug. 11, 2017), ECF No. 24-6; HUD Decl. ¶ 12.

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