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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Theodore Hayes v. Philip Harvey, 903 F.3d 32 (2018)

Citation
Theodore Hayes v. Philip Harvey, 903 F.3d 32 (2018)
Parent Document
Theodore Hayes v. Philip Harvey, 903 F.3d 32 (2018)
Effective Date
2018-08-31

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2014); Letter from Michael Dennis, Dir., Office of Hous.
Voucher Programs, to Exec. Dirs., Public Hous. Agencies
(May 22, 2014); U.S. Dep’t of Hous. & Urban Dev., Section 8
Renewal Policy: Guidance for the Renewal of Project-Based
Section 8 Contracts, § 11-3-B (Feb. 15, 2008) [hereinafter
2008 HUD Renewal Guide]. Indeed, rather than altering its
position, HUD has sought to codify its interpretation through
notice-and-comment rulemaking.           See Tenant-Based
Assistance: Enhanced Vouchers, 81 Fed. Reg. 74,372, 74,374–
75 (Proposed Oct. 26, 2016). That proposed regulation
remains pending. 7