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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

§ 100

Citation
§ 100
Parent Document
Francis v. Kings Park Manor, Inc., 944 F.3d 370 (2019)
Effective Date
2019-12-06

Other Sections in This Document (882)

Full Text

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16  As the Seventh Circuit recognized in declining to rely on the HUD Rule in
Wetzel, “there are salient differences between Title VII and the FHA” and “more analysis
than HUD [has offered]” is needed to support its position. 901 F.3d at 866. In
promulgating the Rule, HUD brushed aside a slew of concerned comments from public
housing providers and their legal counsel. The NYCHA, for instance, warned that the
proposed rule would force public housing providers “to become the guarantor[s] of
resident conduct, as well as the social services provider for mediating disputes,” and that
HUD had “seriously underestimate[d]” the administrative costs, which would end up
diverting resources away from housing providers’ primary responsibility to provide
decent housing. NYCHA Comment. See also Comment of the Council of Large Public