Background
Susan Lloyd leased an apartment in the Eclipse at Belmont in Lancaster, Pennsylvania. She alleged that the landlord treated her unfairly due to her disabilities and her use of federal emergency rental assistance funds. Lloyd claimed the landlord refused direct payments from the Lancaster County Housing Authority and failed to maintain the property, leading to her constructive eviction. She sued the landlord, the housing authority, and other parties in federal court. The District Court dismissed most claims, ruling it lacked subject matter jurisdiction over the housing authority and that the authority was entitled to sovereign immunity. Lloyd withdrew claims against the landlord and appealed the dismissal of her claims against the housing authority.
The court’s reasoning
The court reviewed the dismissal de novo. It agreed with the District Court that the Lancaster County Housing Authority is an arm of the Commonwealth of Pennsylvania and thus entitled to sovereign immunity. The court noted that absent a waiver or congressional abrogation, states and their agencies cannot be sued in federal court. The court found no such waiver or abrogation existed here. Additionally, the court determined that a third pleading amendment would have been futile because the sovereign immunity defense would still bar the claims.
What it means going forward
The decision reinforces that county housing authorities in Pennsylvania are protected by sovereign immunity in federal court unless Congress explicitly abrogates that immunity or the state waives it. Tenants cannot sue these agencies for damages in federal court under these circumstances.