Housing & Redevelopment Insurance Exchange v. Fudge

CourtDistrict Court, M.D. Pennsylvania
DecidedMarch 18, 2025
Docket3:22-cv-01565
StatusUnknown

This text of Housing & Redevelopment Insurance Exchange v. Fudge (Housing & Redevelopment Insurance Exchange v. Fudge) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Housing & Redevelopment Insurance Exchange v. Fudge, (M.D. Pa. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA

HOUSING & REDEVELOPMENT INSURANCE EXCHANGE,

Petitioner, CIVIL ACTION NO. 3:22-cv-01565

v. (SAPORITO, J.)

SCOTT TURNER,1 Secretary of the United States Department of Housing and Urban Development,

Respondent.

MEMORANDUM This is a petition for judicial review of a federal agency administrative adjudication. I. BACKGROUND The petitioner, Housing & Redevelopment Insurance Exchange (“HARIE”) is a reciprocal insurance exchange, an unincorporated non- profit insurance entity organized under Pennsylvania state law. It was originally established in 1985 by a consortium of public housing

1 Scott Turner was confirmed by the United States Senate on February 5, 2025, to serve as Secretary of the U.S. Department of Housing and Urban Development. He has been automatically substituted in place of the original defendant, Marcia Fudge. Fed. R. Civ. P. 25(d). The caption in this case is amended to reflect this change. authorities (“PHAs”) to pool their resources and insure each other’s risks,

presumably for lower premiums than available from outside insurers. Beginning in 1995, HARIE began underwriting insurance for non-PHA municipalities and their political subdivisions as well (e.g., water or

sewer authorities, school districts). Its membership now includes approximately 400 municipal entities. Based on preliminary injunction motion papers filed in this case, about half of HARIE’s insurance policies

are issued to PHAs currently. The respondent is the United States Department of Housing and Urban Development (“HUD”), a cabinet-level federal agency responsible

for national policy and programs addressing the nation’s housing needs. Under federal statutes and regulations, certain HUD programs are administered by PHAs. A standard contract (an “Annual Contributions

Contract”) between HUD and each of these PHAs requires the PHAs to maintain certain insurance coverages. Usually, the required insurance must be obtained through open and competitive bidding. But such

bidding is not required if the PHA purchases insurance from a HUD- approved nonprofit insurance entity owned and controlled by PHAs, referred to as a Qualified PHA-Owned Insurance Entity (“QPIE”). In September 2021, HUD provided notice to HARIE of its intent to

revoke HARIE’s approval as a QPIE pursuant to 24 C.F.R. § 965.205.2 HARIE requested an administrative hearing and discovery was exchanged. HUD filed an administrative complaint setting forth two

bases for revoking HARIE’s approval as a QPIE: (1) HARIE was not exclusively owned and controlled by PHAs (Count 1); and (2) HARIE did not limit participation in its insurance programs to PHAs (Count 2).

On April 26, 2022, an administrative law judge (the “ALJ”) found that a genuine dispute of material fact existed with respect to ownership and control of HARIE, precluding summary judgment on Count 1, but

that, based on the undisputed facts, HUD was entitled to judgment as a matter of law on Count 2, as HARIE undisputedly limit participation in its insurance programs to PHAs. The ALJ’s decision was

upheld on administrative review, and HARIE filed the instant petition for judicial review.

2 This was apparently the third such notice provided to HARIE over the years. HUD provided a similar notice to HARIE in October 2000, with that action subsequently being withdrawn, and in September 2018, but a requested hearing in that proceeding does not appear to have ever been scheduled. II. DISCUSSION The respondent has moved to dismiss this action, and the parties

have briefed the motion and appeared for oral argument before the court. The issue before us is whether the HUD regulation limiting participation to PHAs only, 24 C.F.R. § 965.205(c), exceeds the scope of the authority

granted to the agency by the relevant statute it purportedly implements, 42 U.S.C. § 1436c. HARIE argues that the implementing regulation goes beyond the terms of the statute, imposing an additional substantive

requirement that, to qualify as a QPIE, an insurance entity must limit participation in its insurance programs to PHAs only, when the statute

itself states only that the insurance entity must be “owned and controlled” by PHAs. The respondent, on the other hand, argues that the language of the statute is unambiguous, that the natural and necessary

reading of the phrase “owned and controlled” is that, to qualify as a QPIE, an insurance entity must be owned and controlled by PHAs, and thus that a self-funded insurance entity may not permit non-PHAs

to participate in its insurance programs. In the alternative, the respondent contends that the agency regulation prohibiting participation by non-PHAs is a valid exercise of authority delegated to it by Congress to establish standards for approval of QPIEs under 42 U.S.C. § 1436c, or

the authority more generally delegated to it by Congress to “fill up the details” of the statutory scheme under 42 U.S.C. § 3535(d). Judicial review of HUD’s determination of HARIE’s eligibility for

QPIE status is governed by the Administrative Procedure Act (“APA”), 5 U.S.C. § 701 , 603 U.S. 369, 391 (2024) (“In addition to prescribing procedures for agency action, the

APA delineates the basic contours of judicial review of such action.”). In relevant part, the APA provides that: The reviewing court shall . . . hold unlawful and set aside agency action, findings, and conclusions found to be . . . arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law . . . [or] in excess of statutory jurisdiction, authority, or limitations, or short of statutory right . . . . 5 U.S.C. § 706(2)(A), (C). Although the APA mandates that judicial review of policymaking and factfinding be deferential to the agency findings, , § 706(2)(A) (agency action shall be set aside if “arbitrary, capricious, [or] an abuse of discretion”); § 706(2)(E) (agency factfinding in formal proceedings shall be set aside if “unsupported by substantial evidence”),

agency interpretations of statutes are entitled to deference. , 603 U.S. at 392. “Under the APA, it . . . remains the responsibility of the court to decide whether the law means what the agency says.”

(internal quotation marks omitted); , 467 U.S. 837, 843 n.9 (1984) (“The judiciary is the final authority on issues of statutory construction and must reject

administrative constructions which are contrary to clear congressional intent.”), , 603 U.S. 369. Thus, we begin our statutory analysis by examining the plain

language of the statute. , 662 F.3d 233, 248 (3d Cir. 2011); , 948 F.3d 629, 635 (3d Cir. 2020) (“In determining

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