Department of Housing and Urban Development v. Rucker

Background

Four public housing tenants in Oakland faced eviction under a lease clause that tracks a federal law requiring leases to bar drug-related criminal activity by tenants, household members, guests, or others under the tenant’s control. Local housing officials began state-court eviction actions after incidents including grandsons smoking marijuana in a parking lot, a tenant’s daughter found with cocaine three blocks away, and cocaine found in an apartment occupied by a tenant’s caregiver. The tenants sued HUD and the housing authority and a district judge issued a preliminary injunction blocking evictions when tenants did not know of the drug activity.

Reasoning

The Court addressed whether the federal statute requires proof that the tenant knew about the drug activity before eviction. The Court said the statute’s plain language — especially the word "any" and the listed categories of people — shows Congress required leases that allow eviction without a tenant-knowledge requirement. The Court rejected readings that would attach the phrase "under the tenant’s control" to every category and distinguished a separate forfeiture law that does contain an "innocent owner" defense. The Court also noted HUD rules and a later amendment that broadened the statute’s reach.

Real world impact

The decision means local public housing authorities can have lease clauses allowing termination for household or guest drug crimes even when the tenant was unaware. Housing authorities retain discretion to consider the seriousness of the conduct and other circumstances before evicting. The Supreme Court reversed the appeals court and sent the cases back for further proceedings consistent with this ruling.