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Wright v. City of Roanoke Redevelopment and Housing Authority, 479 U.S. 418, 107 S.Ct. 766, 93 L.Ed.2d 781, 55 USLW 4119

Facts

The tenants, living in low-income housing projects owned by the city redevelopment and housing authority, alleged that the authority overbilled them for utilities, which violated the rent ceiling imposed by the Brooke Amendment to the Housing Act. The District Court ruled that the tenants did not have a private cause of action under § 1983 to enforce the Brooke Amendment, a decision that was upheld by the Court of Appeals. The Supreme Court was asked to determine whether tenants could sue under § 1983 for enforcement of their rights.

Petitioners in this case, tenants living in low-income housing projects owned by respondent, brought suit under 42 U.S.C. § 1983, alleging that respondent overbilled them for their utilities and thereby violated the rent ceiling imposed by the Brooke Amendment to the Housing Act of 1937, and the implementing regulations of the Department of Housing and Urban Development (HUD).

Issue

Did the tenants have a private cause of action under § 1983 to enforce their rights under the Brooke Amendment to the Housing Act?

Did the tenants have a private cause of action under § 1983 to enforce their rights under the Brooke Amendment to the Housing Act?

Rule

The Supreme Court held that nothing in the Housing Act or the Brooke Amendment indicated that Congress intended to preclude a private § 1983 cause of action for the enforcement of tenants' rights secured by federal law.

Nothing in the Housing Act or the Brooke Amendment evidences that Congress intended to preclude petitioners' § 1983 claim against respondent.

Analysis

The Court analyzed the legislative history and statutory language of the Brooke Amendment, concluding that it conferred specific rights on tenants that were enforceable under § 1983. The Court rejected the argument that the provision for a 'reasonable' allowance for utilities was too vague to confer enforceable rights, stating that the benefits intended for tenants were sufficiently specific and definite.

The benefits Congress intended to confer on tenants are sufficiently specific and definite to qualify as enforceable rights under § 1983 and are not beyond the judiciary's competence to enforce.

Conclusion

The Supreme Court reversed the lower court's decision, allowing tenants to pursue their § 1983 claims against the housing authority for overbilling on utilities.

The judgment of the Court of Appeals is accordingly Reversed.

Who won?

The tenants prevailed in the Supreme Court, as the Court recognized their right to bring a private action under § 1983 to enforce their rights under the Brooke Amendment.

The Supreme Court reversed the lower court's decision, allowing tenants to pursue their § 1983 claims against the housing authority for overbilling on utilities.

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