Wojcik v. Lynn Housing Authority

845 N.E.2d 1160, 66 Mass. App. Ct. 103, 2006 Mass. App. LEXIS 422
CourtMassachusetts Appeals Court
DecidedApril 14, 2006
DocketNo. 05-P-204
StatusPublished
Cited by15 cases

This text of 845 N.E.2d 1160 (Wojcik v. Lynn Housing Authority) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wojcik v. Lynn Housing Authority, 845 N.E.2d 1160, 66 Mass. App. Ct. 103, 2006 Mass. App. LEXIS 422 (Mass. Ct. App. 2006).

Opinion

Doerfer, J.

The plaintiff, Patricia Wojcik, receives “section 8”2 benefits, which are administered by the Lynn Housing [104]*104Authority (LHA). In April, 2003, she had occasion to seek the assistance of the LHA over the telephone because of a controversy she was having with her landlord. During the course of this encounter she uttered a threat to the person to whom she was speaking. The LHA subsequently notified her that her benefits were terminated on account of this threatening conduct.

Under a procedure provided for by Federal regulations promulgated by the Department of Housing and Urban Development (HUD) relating to termination of benefits,3 she had a hearing before a hearing officer designated by the LHA. The hearing officer heard evidence that included an account of mitigating circumstances relating to the emotional stress the plaintiff was experiencing and the remorse and quick apologies made by the plaintiff for her admittedly inappropriate behavior. The hearing officer determined that her eligibility for rental subsidy assistance should continue upon certain conditions, relating to her future behavior and counseling.

The LHA decided to disregard the decision of the hearing officer. It claims, in essence, that it and it alone had the authority to decide whether to exercise discretion to take mitigating factors into consideration when confronted with possible terminations of this type and that it was entitled to disregard the decision of the hearing officer.

[105]*105The plaintiff filed a complaint in the Northeast Division of the Housing Court Department challenging the legality of the decision of the LHA to disregard the decision of the hearing officer and to terminate her section 8 benefits. Summary judgment was entered for the plaintiff and her motion for attorney’s fees was allowed. The LHA and its executive director appeal from these rulings.4 The resolution of this dispute requires us to interpret the particular Federal regulations that govern the termination of section 8 benefits by a public housing agency (PHA). Our analysis leads us to conclude that the LHA did not have the authority, on these facts, to disregard the decision of the hearing officer.

1. The record before the hearing officer.5 The hearing officer heard from the plaintiff directly and by way of representations made by her counsel. The LHA appeared by way of a staff person, Barbara Morrison.

Morrison testified that the plaintiff, on April 8, 2003, during a telephone conversation, “threatened to shoot . . . Susan Alfonsi, a case worker for the housing authority.” In particular, it was alleged that the plaintiff said she had a gun and was going to “shoot Ms. Alfonsi’s head off.”

For her part, the plaintiff did not deny she made the threat. Her attorney pointed out that the plaintiff immediately tried to apologize in another telephone call and did in fact do so in a [106]*106letter to the LHA. The notice of termination of her section 8 benefits was thereafter issued, stating that the reason for termination was that she had “engaged in or threatened abusive or violent behavior toward PHA personnel.” The LHA did not seek to learn of or to consider any mitigating circumstances. It took a different view of the substance of a follow-up call by the plaintiff and a subsequent letter of apology.

The hearing officer also considered representations that the plaintiff had been upset with her landlord over lease and rent issues and had been the victim of a violent domestic assault shortly before the incident. Her counsel further represented that her doctor had misprescribed medication, “which contributed to the incident.” Both the plaintiff and her counsel said that she had genuine remorse for the incident. Her counsel “also pointed out that, in addition to [the plaintiff’s] problems, her children had disabilities.”

The plaintiff’s counsel requested reasonable accommodation based on her and her children’s disabilities, including her status as a victim of domestic violence and her mental condition. When asked at the hearing whether the matter could be adjusted, Morrison consulted with David Moore, the person who had issued the termination notice. Moore was not inclined to change the position of the LHA.

The hearing officer concluded in findings that the LHA had discretion to take into account all relevant circumstances. He noted that although the plaintiff did not deny making an inappropriate and threatening statement, she had apologized. He noted that she undertook not to engage in such activity in the future and was aware of the consequences if she did so.

He then decided that she should remain eligible for rent subsidy assistance upon the condition that she refrain from threatening or abusive behavior toward any housing authority member and that she continue to consult with appropriate agencies and medical and other service providers as required.

2. Discussion. We turn first to 24 C.F.R. § 982.555, the material parts of which are set forth in the margin,6 for the source of [107]*107the authority of the PHA to disregard a decision of a hearing [108]*108officer. We note that a PHA cannot disregard such a decision except on grounds set forth in § 982.555(f), which states:

“(f) Effect of decision. The PHA is not bound by a hearing decision:
“(2) Contrary to HUD regulations or requirements, or otherwise contrary to federal, State, or local law.”7

Thus, the issue is whether the hearing officer’s decision was [109]*109“[c]ontrary to HUD regulations or requirements” or “contrary to federal, State, or local law.”8

The claim of the LHA on appeal is that the hearing officer’s decision was contrary to 24 C.F.R. § 982.555(a)(1), which limits the hearing officer’s review to whether the PHA decision was “in accordance with the law, HUD regulations and PHA policies.” The LHA claims that the hearing officer was not authorized by law or the HUD regulations to make a discretionary decision declining to terminate benefits.9 To address this argument we must analyze the relevant regulations.

a. Regulations bearing on the informal hearing. We note first that where the PHA terminates benefits based on threats by a family member, it must provide to the family an opportunity for an informal hearing. 24 C.F.R. §§ 982.555(a)(l)(v), 982.552(c)(l)(ix). We further note that a hearing may be offered but is not required where the PHA takes certain types of adverse action relating to benefits. 24 C.F.R. § 982.555(b). These include such things as a determination not to approve an extension of a voucher term, or a decision that a unit is not in compliance with housing quality standards (unless the claim is that the lack of compliance was caused by the family as described in § 982.55l[c]).

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Bluebook (online)
845 N.E.2d 1160, 66 Mass. App. Ct. 103, 2006 Mass. App. LEXIS 422, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wojcik-v-lynn-housing-authority-massappct-2006.