Spady Et Vir v. Mount Vernon Housing Authority

Background

A married couple, Linda and Vincent Spady, applied for low-income public housing in Mount Vernon, New York. They were told they were eligible, signed a lease, paid rent and a security deposit, and were assigned an apartment to begin occupancy on July 15, 1971. Before move-in, the housing authority learned Vincent had once used the name Vincent Bentley and had arrests in the past; those arrests were later dismissed and he had undergone narcotics treatment and was in a methadone program.

Reasoning

The Housing Authority revoked the Spadys’ eligibility, saying the application had been “untruthful,” and denied their request for an evidentiary hearing. A state trial court ordered a hearing, but a divided intermediate appellate court reversed, finding no right to a hearing and concluding the revocation had a rational basis; the state’s highest court affirmed by memorandum. The Supreme Court declined to grant review, issuing a one-line denial of the petition for certiorari and therefore did not decide the merits of the dispute.

Real world impact

Because the Supreme Court refused to take the case, the lower courts’ rulings remain in place and the housing authority’s action stands in this matter. The couple lost their immediate place and any practical expectation of the apartment, and other applicants similarly removed shortly before occupancy may face similar results. This denial is procedural — it does not resolve whether agencies must hold hearings in such disputes, so the legal question could come up again.

Dissents or concurrances

Justice Douglas dissented from the denial, arguing the Spadys had a substantial interest and deserved a hearing before losing housing eligibility, and that removing people without a hearing risks arbitrary administrative power.