Newark Housing Authority Claremont v. Ty-Taniesha Wilder

New Jersey Superior Court Appellate Division·Decided December 4, 2023·No. A-3795-21·Unpublished

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3795-21

NEWARK HOUSING AUTHORITY CLAREMONT,

Plaintiff-Respondent,

v.

TY-TANIESHA WILDER,

Defendant-Appellant. __________________________

Submitted November 9, 2023 – Decided December 4, 2023

Before Judges Firko & Susswein.

On appeal from the Superior Court of New Jersey, Law Division, Essex County, Docket No. LT-004866-21.

Rutgers Economic Justice and Public Benefits Clinic, attorneys for appellant (Victor Manuel Monterrosa Jr., of counsel and on the briefs; Sarah Choudhry, and Nicholas Willette, appearing pursuant to Rule 1:21-3 (b), on the briefs).

Ehrlich, Petriello, Gudin, Plaza & Reed, PC, attorneys for respondent (Nicholas Mesarick, on the brief).

PER CURIAM This appeal stems from a June 27, 2022 eviction from federally subsidized

housing. Defendant Ty-Taniesha Wilder and her three minor children lived in

plaintiff Newark Housing Authority Claremont's multi-unit housing complex

located in Newark under Section 8 regulations, 24 C.F.R. §§ 982.1 to -982.643,

promulgated by the United States Bureau of Housing and Urban Development

(HUD). Defendant is the head of household and primary voucher holder. 24

C.F.R. § 982.302(a).

Plaintiff initiated a removal action under the Anti-Eviction Act, N.J.S.A.

2A:18-61.1(d) and (e), on the basis of breach of lease because defendant failed

to annually re-certify her income and expenses as required under Section

VII(c)(1) and (2) of the lease. We affirm.

I.

The essential facts are not in dispute. At the time this action commenced,

plaintiff owned the residential housing complex. On April 20, 2018, defendant

entered into a residential lease agreement with plaintiff. Section 10.2 of the

lease requires the composition of the household to be stated as approved by

plaintiff, in conformity with 24 C.F.R. 966.4(a)(1)(v), which requires the family

to "request [plaintiff's] approval to add any other member as an occupant of the

unit." Defendant was identified as head of household, and two of her three minor

A-3795-21 2 children, D.W.1 and S.H., were listed on the lease as members of defendant's

household authorized to occupy the premises. The lease is renewed annually by

a rider that must be signed by all adult household members. T.M. was born

while defendant was occupying the unit. Defendant's mother was also living at

the premises as an unauthorized occupant.

HUD subsidizes the rent in plaintiff's building. Plaintiff offers families

the choice between a flat rent and an income-based rent. Section 12.3 of the

lease incorporates a HUD-required certification; to retain their subsidy, tenants

must annually certify information relating to income, expenses, and occupancy.

Plaintiff reexamines the families' incomes once a year if income-based rent is

paid, as in the matter under review.

Plaintiff conducts annual re-certifications by interviewing adult members

and verifying their income and asset information, deductions, family size, and

composition. Failure to properly certify the information results in a breach of

the lease and termination of assistance. The HUD Handbook section 7-8(A)

provides, "In general, re[-]certification processing should be complete by the

re[-]certification anniversary date." When a tenant is out of compliance with

1 We use initials to protect the identity of the minor children. D.W. turned eighteen years of age in May 2023 while this appeal was pending. A-3795-21 3 the re-certification requirements, the tenant is projected to be evicted. HUD

Handbook section D(3)(b).

Between December 2020 and February 2021, defendant ignored three re-

certification notices, which were personally delivered and mailed to her. On

December 10, 2020, the first re-certification letter was sent to defendant with a

scheduled appointment. On February 10, 2021, a second re-certification letter

was sent to defendant and stated: "Failure to appear for this re-scheduled

appointment may result in termination of your lease and eviction." On February

19, 2021, a third re-certification letter was sent to defendant and stated: "You

failed to attend two scheduled re-certification appointments. A third re-

certification appointment is scheduled for you on February 22, 2021, at 10:00

a.m." Attached to the third letter was a notice to cease and notification that

plaintiff had commenced an action to terminate the lease.

On April 12, 2021, after the notices were sent, defendant was arrested and

incarcerated at the Essex County Correctional Facility where she is currently

detained. Defendant's mother continues to reside in the unit with the children.

It is undisputed defendant failed to re-certify and missed the in-person re-

certification meetings scheduled before and during the COVID-19 pandemic and

prior to her incarceration. During that time, plaintiff refused to accept rent on

A-3795-21 4 two occasions—on or about April 22, 2021, and May 20, 2021—from D.W.,

who is defendant's eldest daughter and a remaining occupant at the unit. D.W.

was sixteen years old at the time and went to plaintiff's management office to

pay the rent.

Thereafter, defendant sought to have D.W. become head of household,

perform the re-certification, and sign a new lease in her stead while she was

incarcerated and her criminal case was pending, citing 24 C.F.R. § 982.308 (a).2

Head of household "means the adult member of the family who is the head of

household for purposes of determining income eligibility and rent." 24 C.F.R.

§ 5.504. Plaintiff declined to permit D.W. to become head of household because

she was not eighteen years old as required under its Admissions and Continued

Occupancy Policy (ACOP) and 24 C.F.R. § 5.902, which defines an adult "as a

person who is [eighteen] years of age or older. . . ." ACOP defines "head of

household" as

the adult member of the family who is considered the head for purposes of determining income eligibility and rent. The head of household is responsible for ensuring that the family fulfills all of its responsibilities under the program, alone or in conjunction with a co-head or

2 24 C.F.R. 982.308(a) addresses a tenant's legal capacity and provides: "The tenant must have legal capacity to enter a lease under State and local law. 'Legal capacity' means that the tenant is bound by the terms of the lease and may enforce the terms of the lease against the owner." A-3795-21 5 spouse. [24 C.F.R. 5.504(b)].

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