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Davis v. Woonsocket Hous. Auth
No. C.A. 98-601 (D. R.I. Dec. 28, 1998). ; Clearinghouse Number: 52270
Description
Pending Hearing on Motion for Injunctive Relief, Housing Authority Must Not Issue or Enforce Trespass Notices Served on Tenant’s Invitees
Abstract
Pending a hearing on plaintiffs’ motion for injunctive
relief, the district court entered a consent order enjoining
defendant housing authority both from serving any trespass notice
on any acknowledged invitee of any tenant and from enforcing such
trespass notices without reasonable notice and an opportunity to be
heard. Plaintiffs are two tenants of and two of tenants’
invitees to properties owned or managed by defendant city housing
authority. On separate occasions defendant served trespass notices
on tenants’ invitees as they were driving through
defendant’s housing developments on their way to visit
tenants and their children. The notices purport to forbid invitees
from "trespass[ing] upon the land or any premises owned by
[defendant] housing authority" and state that any willful
trespass after notice is punishable by a fine of up to $1,000,
imprisonment of up to one year, or both. The notices offer no
reason why they were served. After unsuccessful attempts to have
the notices vacated by housing authority, plaintiffs filed suit.
Plaintiffs alleged that housing authority’s abuse of trespass
notices unlawfully interfered with their contractual and common-law
right to quiet enjoyment of the rented premises; the U.S. Housing
Act and Department of Housing and Urban Development regulations
required the authority to allow tenants to have guests. They
alleged that the notices violated their fundamental rights to
privacy and free association under the First, Ninth, and Fourteenth
Amendments and the state constitution. By failing to give notice or
a hearing before serving the trespass notices, plaintiffs claimed
that defendant also violated their due process rights.
