Terkel v. Centers for Disease Control and Prevention

CourtDistrict Court, E.D. Texas
DecidedFebruary 25, 2021
Docket6:20-cv-00564
StatusUnknown

This text of Terkel v. Centers for Disease Control and Prevention (Terkel v. Centers for Disease Control and Prevention) is published on Counsel Stack Legal Research, covering District Court, E.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Terkel v. Centers for Disease Control and Prevention, (E.D. Tex. 2021).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS No. 6:20-cv-00564 Lauren Terkel et al., Plaintiffs, V. Centers for Disease Control and Prevention et al., Defendants.

OPINION AND ORDER This lawsuit presents the question whether the federal government has authority to order property owners not to evict specified tenants. Plaintiffs argue that this authority is not among the limited powers granted to the federal govern- ment in Article I of the Constitution, and thus the decision whether to enact an eviction moratorium rests with a given State. Disagreeing, the federal government argues that a na- tionwide eviction moratorium is within Article I’s grant of federal authority to regulate commerce among the States. Only that issue is posed here. This lawsuit does not ques- tion that the States may regulate residential evictions and foreclosures, as they have long done. For instance, during the Great Depression, 27 States enacted foreclosure moratoriums and other laws meant to mitigate the effects of a wave of fore- closures. Geoff Walsh, The Finger in the Dike: State and Local Laws Combat the Foreclosure Tide, 44 Suffolk U. L. Rev. 139, 139- 43 (2011). In upholding one such law against a challenge not raised here, the Supreme Court recognized the “control which the state retains over remedial processes” in this area as part of the State’s “police power, [which] is an exercise of the sov- ereign right of the government to protect the lives, health, morals, comfort, and general welfare of the people.” Home Bldg. Ass’n v. Blaisdell, 290 U.S. 398, 434, 437 (1934).

But while “[t]he States have broad authority to enact leg- islation for the public good—what we have often called a ‘po- lice power’”—“[t]he Federal Government, by contrast, has no such authority[.]” Bond v. United States, 572 U.S. 844, 854 (2014). The question here is whether a nationwide moratorium on evicting specified tenants is within the limited powers that our Constitution grants to the federal government, namely, its authority to legislate as necessary and proper to regulate com- merce among the several States. The federal government cannot say that it has ever before invoked its power over interstate commerce to impose a resi- dential eviction moratorium. It did not do so during the deadly Spanish Flu pandemic. Hr’g Tr. (Doc. 21) at 52:3-8 (government’s representation). Nor did it invoke such a power during the exigencies of the Great Depression. Id. The federal government has not claimed such a power at any point during our Nation’s history until last year. Id. at 55:9-17. And the government’s claim of constitutional authority is broad. The government admits that nothing about its consti- tutional argument turns on the current pandemic: THE COURT: [T]here’s nothing special about COVID 19? Congress could do the same thing, the same temporary suspension of tenant evictions, if there was an inability to pay rent because of some other rea- son that Congress finds important? My example was cohabitating spouses sent to prison, but there could be others. That is your Commerce Clause argument; cor- rect? MS. VIGEN: That is our Commerce Clause argu- ment, correct. Hr’g Tr. at 56:13-21. The federal government thus claims au- thority to suspend residential evictions for any reason, includ- ing an agency’s views on “fairness.” Id. at 53:11-23. Given the open-textured nature of the relevant constitu- tional text, “the question of congressional power under the Commerce Clause ‘is necessarily one of degree.’” United States v. Lopez, 514 U.S. 549, 566 (1995) (quoting NLRB v. Jones & Laughlin Steel Corp., 301 U.S. 1, 37 (1937)). Reasonable minds may differ given the lack of “precise formulations.” Id. at 567. But here, after analyzing the relevant precedents, the court concludes that the federal government’s Article I power to regulate interstate commerce and enact laws necessary and proper to that end does not include the power to impose the challenged eviction moratorium. Background 1. COVID-19 is a disease “caused by a new coronavirus first identified in Wuhan, China, in December 2019.” See Cen- ters for Disease Control and Prevention, About COVID-19 (Sept. 1, 2020), www.cdc.gov/coronavirus/2019-ncov/cdcresp onse/about-COVID-19.html. “Although most people who have COVID-19 have mild symptoms, COVID-19 can also cause severe illness and even death.” Id. The disease “is thought to spread mainly through close contact from person to person.” See Centers for Disease Control and Prevention, How COVID-19 Spreads (Oct. 28, 2020), www.cdc.gov/corona virus/2019-ncov/prevent-getting-sick/how-covid-spreads.html. The public and private response to COVID-19 has led to busi- ness disruptions for many. On March 27, 2020, the President signed into law the Coro- navirus Aid, Relief, and Economic Security Act. Pub. L. No. 116-136, 134 Stat. 281 (2020) (the CARES Act). Among other things, the Act included a 120-day prohibition on the initia- tion of eviction proceedings for “covered properties,” defined as those participating in specified federal programs or with specified federally backed loans. Id. § 4024, 134 Stat. at 492-93. Congress did not renew the CARES Act, and the Act’s evic- tion moratorium lapsed on July 27, 2020. A number of States, however, have eviction moratoria or rent-assistance programs of their own. As noted, this lawsuit does not call into question state and local-government measures. In September 2020, the Centers for Disease Control and Prevention—a component of the U.S. Department of Health and Human Services—issued the agency order challenged here. Temporary Halt in Residential Evictions to Prevent the Further Spread of COVID-19, 85 Fed. Reg. 55,292 (Sept. 4, 2020). The order was originally set to expire on December 31, 2020. Id. at 55,297. Federal legislation then extended the or- der’s expiration date to January 31, 2021. Consolidated Ap- propriations Act, 2021, Pub. L. No. 116-260, § 502, 134 Stat. 1182, 2078-79 (2020). A subsequent agency order further ex- tended the eviction moratorium, with minor modifications and additional findings, to be effective through the end of March 2021. Temporary Halt in Residential Evictions to Pre- vent the Further Spread of COVID-19, 86 Fed. Reg. 8,020, 8,021 (Feb. 3, 2021) (“This Order further extends and modifies the prior Orders until March 31, 2021[.]”). No party argues that supplemental pleading is necessary to give fair notice of plaintiffs’ continuing challenge to the order as extended, which the government agrees “is identical in substance and effect” to the original order. Doc. 42 at 2; accord Doc. 43 at 2. The CDC order generally makes it a crime for a landlord or property owner to evict a “covered person” from a resi- dence. 86 Fed. Reg. at 8,020.

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Bluebook (online)
Terkel v. Centers for Disease Control and Prevention, Counsel Stack Legal Research, https://law.counselstack.com/opinion/terkel-v-centers-for-disease-control-and-prevention-txed-2021.