Sager v. Housing Commission, 855 F. Supp. 2d 524

Background

Melissa Sager, a public housing tenant in Anne Arundel County, sues the Housing Commission and two officials alleging federal and Maryland law violations.
The Housing Commission operates public housing under the U.S. Housing Act and HUD regulations, including lease terms and grievance procedures.
Sager’s lease in 2010–2011 cited numerous alleged lease violations, leading to a Vacate Agreement and termination notice, and later a Breach of Lease action.
Plaintiff alleges improper collection of charges, misapplication of payments, and coercive conduct by the Commission’s staff related to lease termination and evictions.
Plaintiff also asserts disability discrimination claims under the Fair Housing Act and a due process claim, all under 42 U.S.C. § 1983, with damages and declaratory relief sought.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Abstention by federal court warranted?	Younger/ Wilton abstention should apply due to pending state case.	Abstention appropriate because of ongoing state proceedings and issues of state interest.	Younger abstention not warranted; no ongoing state proceeding and federal interests prevail.
Whether the lease payment allocation provision constitutes a confessed judgment or violates law	Lease allows applying non-rent payments to charges, effectively enabling confession of judgment.	Provision is not a confession of judgment and complies with federal regulations.	Provision is not a confession of judgment; Counts II and部分I/III limited; treble damages barred.
Exhaustion of administrative remedies for public housing grievances	Administrative grievance process must be exhausted before judicial review.	Exhaustion not required for public housing grievance; remedies are available in court.	Exhaustion doctrine does not apply to the public housing grievance procedure; claims may proceed in court.
Disability discrimination and reasonable accommodation under FHA	Defendant failed to provide reasonable accommodation; prevention of equal housing opportunity.	Offers of accommodation and transfer options negate claim; summary judgment warranted.	Summary judgment denied without prejudice as to Count IV; further record needed on reasonableness of accommodations.
Grievance process deficiencies and due process under Housing Act	Written decision lacked reasons; potential bias; informal hearing witness issue.	Procedural issues may be cured by Breach of Lease proceedings; some issues premature.	Some grievance-defect claims viable (written decision deficiency, bias concerns), others dismissed; remaining issues reserved.

Key Cases Cited

Wright v. City of Roanoke Redevelopment & Hous. Auth., 479 U.S. 418 (U.S. 1987) (enforceability of Housing Act rights via § 1983; Brooke Amendment context cited)
Anderson v. XYZ Corr. Health Servs., Inc., 407 F.3d 674 (4th Cir. 2005) (no exhaustion requirement in § 1983 context generally)
Nivens v. Gilchrist, 444 F.3d 237 (4th Cir. 2006) (Younger abstention considerations in state-focused disputes)
Wilton v. Seven Falls Co., 515 U.S. 277 (U.S. 1995) (declaratory-judgment abstention factors; Brillhart-Wilton framework)
Monell v. Dept. of Soc. Servs. of City of N.Y., 436 U.S. 658 (U.S. 1978) (local government liability under § 1983; policy/custom requirement)