§ 9058

Citation: § 9058
Parent Document: Hous. Auth. v. Knight, 563 P.3d 1058 (2025)
Jurisdiction: Washington (state)
Effective Date: 2025-02-20
Original Source: https://www.courtlistener.com/opinion/10336415/hous-auth-v-knight/ ↗

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rule to federal housing statutes would “pit one constitutional value against another: federalism”
and Congress’s spending power. Id. at 20-22. While the Supreme Court has not applied the
clear statement rule to federal housing statutes, Knight is incorrect that it plays no role under the
spending clause. “[I]f Congress desires to condition the States’ receipt of federal funds, it ‘must
do so unambiguously . . . , enabl[ing] the States to exercise their choice knowingly, cognizant of
the consequences of their participation.’” South Dakota v. Dole, 483 U.S. 203, 207, 107 S. Ct.
2793, 97 L. Ed. 2d 171 (1987) (alterations in original) (quoting Pennhurst State Sch. & Hosp. v.
Halderman, 451 U.S. 1, 17, 101 S. Ct. 1531, 67 L. Ed. 2d 694 (1981)). This limitation requires
Congress to be “clear about the obligations it is imposing” on states and takes the form of a
“‘clear statement’ rule.” Terry J. Seligmann, Muddy Waters: The Supreme Court and the Clear
Statement Rule for Spending Clause Legislation, 84 TUL. L. REV. 1067, 1069 (2010).
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 Hous. Auth. v. Knight, No. 102905-5

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