The Supreme Court of Connecticut decided that a pretermination notice for a Section 8 project-based lease based on nonpayment of rent could not, under HUD regulations and the HUD Handbook, include other fees related to eviction such as attorney's fees and utilities. Presidential Village, LLC v. Perkins, -A.3d-, 332 Conn. 45, 2019 WL 2495491, (SC 20043) (Conn. June 18, 2019). Presidential Village, LLC, owns Presidential Village, a HUD Section 8 project-based New Haven housing development for low income families. Tonya Perkins signed a HUD model lease for an apartment in Presidential Village for a term running from March 2, 2010 to February 28, 2011, and thereafter " 'continu[ing]' for successive terms of one month . . .." 2019 WL 2495491 at *3. Defendant's rent was set at $377 per month, not inclusive of the amount of HUD's subsidy. The lease stated that the rent could increase (or decrease) for various reasons, including a change in income as determined in the annual recertification of income. However, the rent had a ceiling of 30% of the tenant's income. 42 U.S.C.A. § 1437a (a) (1) (2012).
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