Theodore Hayes v. Philip Harvey (2018)

Citation: Theodore Hayes v. Philip Harvey (2018)
Parent Document: Theodore Hayes v. Philip Harvey (2018)
Jurisdiction: United States (federal)
Effective Date: 2018-08-31
Original Source: https://www.courtlistener.com/opinion/4532088/theodore-hayes-v-philip-harvey/ ↗

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of landlord-tenant relations: During the term of their lease,
tenants generally may not be evicted, absent some reason
enumerated in the lease or authorized by law; at the end of their
lease term, tenants may seek to renew their leases, as long as
their landlords agree to do so. Thus, if enhanced voucher
holders’ right to “elect to remain” limited property owners’
rights during only the lease term, the first clause of the
provision would have no independent meaning; it would
describe what was already true. It is, however, a well-
established canon of statutory interpretation that “statutes
should be read to avoid making any provision ‘superfluous,
void, or insignificant.’” Milner v. Dep’t of the Navy, 562 U.S.
562, 575 (2011) (quoting TRW Inc. v. Andrews, 534 U.S. 19,
31 (2001)).

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