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HomeMy WebLinkAbout2010-2688 Civil THERESA SMEE, : IN THE COURT OF COMMON PLEAS OF Appellant : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION : CUMBERLAND/PERRY : HOUSING AND COMMUNITY : PARTNERSHIP, : Appellee : NO. 10-2688 CIVIL TERM IN RE: APPELLANT’S APPEAL FROM DETERMINATION OF THE CUMBERLAND/PERRY HOUSING AND COMMUNITY PARTNERSHIP TERMINATING APPELLANT’S PARTICIPATION IN THE SECTION 8 HOUSING CHOICE VOUCHER PROGRAM BEFORE OLER, J. OPINION and ORDER OF COURT OLER, J., July 21, 2010. In this case involving an appeal from a local agency determination, Theresa Smee (Appellant) challenges a termination of her participation in a federal “Section Eight” rental assistance program administered by the Cumberland/Perry Housing and Community Partnership (Appellee). The termination resulted from her felony conviction for unlawful possession with intent to deliver a Schedule I Controlled Substance (marijuana). While not contesting that in appropriate circumstances the commission of 1 such a crime can result in a termination, Appellant contends that such a result was not warranted in her case because (a) she was not “currently engaged” in the unlawful 2 activity when terminated, as purportedly required in a policy adopted by the agency and/or (b) the circumstances in her case were not sufficiently egregious as to reasonably 3 justify the result. A hearing was held on the appeal on May 18, 2010. For the reasons stated in this opinion, Appellee’s determination will be affirmed. 1 Appellant’s Responsive Trial Brief, submitted June 23, 2010, at 1. 2 Appellant’s Responsive Trial Brief, submitted June 23, 2010, at 3-5. 3 Appellant’s Responsive Trial Brief, submitted June 23, 2010, at 7. STATEMENT OF FACTS The facts pertinent to this appeal are not substantially in dispute and may be summarized as follows: Appellant is an adult individual who became a participant about six years ago in the “Section Eight” Housing Choice Voucher Program provided for in the United States 4 Housing Act of 1937, as amended. Appellee is a Public Housing Agency (PHA) under 5 the law, with offices at 114 North Hanover Street, Carlisle, Cumberland County, 6 Pennsylvania. In the Housing Act, Congress declared that it is this nation’s policy to employ its funds to “remedy the unsafe housing conditions and the acute shortage of decent, safe and affordable dwellings for low income families”, and to vest responsibility, flexibility and accountability in the PHAs, the entities that administer the programs which provide federal housing assistance. . . . Section 8 7 assistance is provided to those who lease a dwelling in the private sector. The United States Department of Housing and Urban Development is authorized pursuant to the act to promulgate regulations with respect to the termination of such assistance. See Powell v. Housing Authority of City of Pittsburgh, 571 Pa. 552, 812 A.2d 1201 (2002). Among the regulations promulgated by the Department is the following: Terminating assistance—(1) Terminating assistance for drug criminals . . . The PHA must establish standards that allow the PHA to terminate assistance under the program for a family if the PHA determines that any family member has violated the family’s obligation under [24 C.F.R.] §982.551 not to engage in any drug- 8 related criminal activity. One of the “family[] obligation[s]” under the regulations relates to “[c]rime by household members” and provides that “[t]he members of the household may not engage 9 in drug related activity . . . .” Under the act, “drug related activity” includes “the 4 Notes of Testimony, 5, Hearing, May 18, 2010 (hereinafter N.T. ___). 5 35 P.S. §1541; see 24 C.F.R. 982.4 (1998) 6 Appeal from Determination of the Cumberland/Perry Housing and Community Partnership Terminating Appellant’s Participation in the Section 8 Housing Choice Voucher Program, ¶2, Ex. A; see Appellee’s Ex. 7, Hearing, May 18, 2010. 7 Powell v. Housing Authority of City of Pittsburgh, 571 Pa. 552, 555-56, 812 A.2d 1201, 1203 (2002). 8 24 C.F.R. 982.553(b)(1)(iii). 9 24 C.F.R. 982.551(l). 2 illegal . . . possession with intent to . . . distribute . . . a controlled substance . . . .” 42 U.S.C. 1437f(f). Pursuant to the HUD mandate, Appellee adopted an administrative plan which included the following standards relating to termination of assistance for drug-related activity: The PHA will terminate a family’s assistance if any household member has violated the family’s obligation not to engage in any drug related . . . activity 10 during participation in the HCV program. * * * * Criminals – Assistance must be terminated if any household member is currently 11 engaged in any . . . drug related criminal activity. The plan also made mere use of an illegal drug, without more, by a household 12 member a ground for termination, where the use was being “currently engaged in.” “Currently engaged in” was defined as “any use of illegal drugs during the previous six 13 months.” Finally, a Notice of Obligations Form utilized by Appellee advised applicants for tenant-based assistance as follows: THE FAMILY (INCLUDING EACH FAMILY MEMBER) MUST NOT . . .[p]articipate in illegal drug . . . activity. Such illegal participation may 14 result in denial or termination of rental assistance. At the time of her admission into the program, Appellant signed a copy of the Notice of Obligations, expressly acknowledging her understanding “that failure of the family to meet the conditions contained in this statement will be a basis for termination of rental assistance under the program, and may be a basis for denying the family the right 15 to participate in the program in the future.” 10 Appellee’s Ex. 1, Hearing, May 18, 2010; N.T. 8-9. 11 Appellee’s Ex. 5, Hearing, May 18, 2010. 12 Appellee’s Ex. 5, Hearing, May 18, 2010; Appellee’s Ex. 3, Hearing May 18, 2010. 13 Appellee’s Ex. 1, Hearing, May 18, 2010; Appellee’s Ex. 5, Hearing May 18, 2010. 14 Appellee’s Ex. 2, Hearing, May 18, 2010. 15 Appellee’s Ex. 2, Hearing, May 18, 2010, N.T. 13. 3 While participating with her two minor children in the tenant-based rental assistance program administered by Appellee, on August 6, 2009, Appellant took marijuana to the state correctional institution in Camp Hill, Cumberland County, 1617 Pennsylvania, with the intent to deliver it to her boyfriend, an inmate, who according 18 to her had “some mental health issues.” She was arrested before the delivery could be 19 accomplished, pled guilty to a felony charge of possession of a Schedule I Controlled 20 Substance with intent to deliver on January 14, 2010, and was sentenced to a period of 21 probation on February 16, 2010. Appellee learned of the incident through a newspaper 22 article on the sentencing, and by notice dated March 4, 2010, advised Appellant of her 23 termination from the program effective April 30, 2010. Appellant exercised her right to a counseled administrative review of the 24 termination, with an unsuccessful result dated April 12, 2010. She filed an appeal to this 25 court on April 22, 2010. An evidentiary hearing was held on the appeal on May 18, 2010. DISCUSSION Statement of law. The standard of review involving agency adjudications is limited to a determination of whether constitutional rights have been violated, errors of law have been committed, and the agency’s necessary findings of fact are supported by substantial 16 This state prison, while in Cumberland County, is not in the immediate vicinity of Appellant’s residence. N.T. 17. 17 N.T. 5. 18 N.T. 7. The court did not find credible Defendant’s claim that she had changed her mind about delivering the controlled substance prior to her arrest at the prison. See N.T. 7. 9. 19 N.T. 6. 20 Appellee’s Ex. 4, Hearing, May 18, 2010. 21 Appellee’s Ex. 6, Hearing, May 18, 2010. 22 N.T. 13-14. 23 Appellee’s Ex. 3, Hearing, May 18, 2010. 24 Appellee’s Ex. 7, Hearing, May 18, 2010; N.T. 24. 25 Appeal from Determination of the Cumberland/Perry Housing and Community Partnership Terminating Appellant’s Participation in the Section 8 Housing Choice Voucher Program, filed Apr. 22, 2010. 4 evidence. Bethenergy Mines, Inc. v. Workers’ Comp. Appeal Bd. (Skirpan), 531 Pa. 287, 612 A.2d 434 (1992); Ins. Fed’n of Pennsylvania, Inc. v. Commonwealth, Dep’t of Ins., 585 Pa. 630, 889 A.2d 550 (2005); see Act of April 28, 1978, P.L. 202, §5, 2 Pa. C.S. §704. In this context, substantial evidence has been defined as “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Peak v. Commonwealth, Unemployment Comp. Bd. of Review, 509 Pa. 267, 275 501 A.2d 1383, 1387 (1985) (citations omitted). Furthermore, where an action of the agency is discretionary, the fact that the reviewing court might reach an opinion or judgment other than the one reached by the agency is not a sufficient ground for interference with the agency’s determination; judicial discretion may not be substituted for administrative discretion. Norfolk and W. Ry. Co. v. Pennsylvania Pub. Util. Comm’n, 489 Pa. 109, 128, 413 A.2d 1037, 1047 (1980), citing Blumenschein v. Housing Auth. of Pittsburgh, 379 Pa. 566, 573, 109 A.2d 331, 334-35 (1954). Finally, it is well settled that an administrative agency is particularly suited to interpret the meaning of its own policies. See Norfolk & W. Ry. Co. v. Pennsylvania Pub. Util. Comm’n, 489 Pa. 109, 413 A.2d 1037 (1980); Commonwealth v. Beck Elec. Constr., Inc., 485 Pa. 604, 403 A.2d 553 (1979); W.J. Dillner Transfer Co. v. Pennsylvania Pub. Util. Comm’n, 175 Pa. Super. 461, 107 A.2d 159 (1954); Application of law to facts. In the present case, although the administrative policy of Appellee with respect to termination of rental assistance for drug related criminal activity may not be a model of clarity it seems clear at least (a) that under the policy the agency reserved to itself the authority, inter alia, to terminate a person’s rental assistance where a household member engaged in drug related criminal activity in the form of possession with intent to deliver a controlled substance at any time during the course of his or her participation in the program, (b) that such a reservation of authority was not only permitted but mandated under regulations promulgated by the Department of Housing and Urban Development, (c) that such regulations by HUD were authorized 5 pursuant to the federal statute in question, and (d) that Appellant was apprised of this reservation of authority at the time she was admitted into the program. Under these circumstances, the court can not say that the action of Appellee in terminating Appellant’s participation in the federal tenant-based rental assistance program as a result of her drug related criminal activity while receiving the benefits of the program was without legal foundation. In challenging the agency’s determination as an abuse of discretion, Appellant argues that the offense represented a “momentary lapse in judgment,” “does not foreshadow any further problems with drug-related criminal activity,” and “should be 26 overturned in consideration of the circumstances surrounding her arrest.” However, as noted above, the offense unquestionably represented drug related criminal activity, was a felony of a fairly serious nature in terms of the risk it posed to public order, and was arguably much less deserving of leniency in terms of a continuation of taxpayer support than would have been the mere use of marijuana off-premises by Appellant for a personal recreational purpose on one occasion. Under these circumstances, a substitution of the court’s judgment for that of Appellee would, in the court’s view, be inconsistent with the principle of judicial deference in such matters to the sound discretion of agencies. For the foregoing reasons, the court is constrained to enter the following order: ORDER OF COURT st AND NOW, this 21 day of July, 2010, upon consideration of Appellant’s Appeal from Determination of Cumberland/Perry Housing and Community Partnership Terminating Appellant’s Participation in the Section 8 Housing Choice Voucher Program, and following a hearing held on May 18, 2010, Appellant’s appeal is denied, and Appellee’s determination is affirmed. 26 Appellant’s Responsive Trial Brief, submitted June 23, 2010, at 8. 6 BY THE COURT, s/ J. Wesley Oler, Jr. J. Wesley Oler, Jr., J. Geoffrey M. Biringer, Esq. MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 Attorney for Appellant Tricia Naylor, Esq. 104 South Hanover Street Carlisle, PA 17013 Attorney for Appellee 7 8 THERESA SMEE, : IN THE COURT OF COMMON PLEAS OF Appellant : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION : CUMBERLAND/PERRY : HOUSING AND COMMUNITY : PARTNERSHIP, : Appellee : NO. 10-2688 CIVIL TERM IN RE: APPELLANT’S APPEAL FROM DETERMINATION OF THE CUMBERLAND/PERRY HOUSING AND COMMUNITY PARTNERSHIP TERMINATING APPELLANT’S PARTICIPATION ON A SECTION 8 HOUSING CHOICE VOUCHER PROGRAM BEFORE OLER, J. ORDER OF COURT st AND NOW, this 21 day of July, 2010, upon consideration of Appellant’s Appeal from Determination of Cumberland/Perry Housing and Community Partnership Terminating Appellant’s Participation in the Section 8 Housing Choice Voucher Program, and following a hearing held on May 18, 2010, Appellant’s appeal is denied, and Appellee’s determination is affirmed. BY THE COURT, _________________ J. Wesley Oler, Jr., J. Geoffrey M. Biringer, Esq. MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 Attorney for Appellant Tricia Naylor, Esq. 104 South Hanover Street Carlisle, PA 17013 Attorney for Appellee