## Facts

- Cuyahoga Metropolitan Housing Authority (CMHA) is a public housing authority responsible for developing and administering low-income housing in Cuyahoga County, Ohio.
- Cleveland City Council enacted Ordinance No. 836-71 authorizing a cooperation agreement with CMHA for development and administration of 2,500 low-income dwelling units.
- The Mayor executed the written 1971 Cooperation Agreement on behalf of the City.
- The agreement functioned within a federally administered public housing program involving HUD, including certification of the City’s “Workable Program,” which yielded program benefits to the City.
- CMHA took substantial steps in reliance on the agreement, including multi-phase planning, obtaining HUD program reservations for initial units, and expanding staff to implement the development.
- City Council later enacted Ordinance No. 392-72 purporting to repeal Ordinance No. 836-71 and cancel the Cooperation Agreement.
- CMHA sued for declaratory and injunctive relief, asserting the attempted cancellation conflicted with federal housing law and the Supremacy Clause.

## Issues

1. Whether a municipality may unilaterally repeal an ordinance and cancel an executed cooperation agreement supporting a HUD-related public housing program after the housing authority and federal program processes have proceeded in reliance on that agreement.
2. Whether the attempted cancellation is invalid under the Supremacy Clause because it conflicts with the objectives and operation of the federal public housing scheme.

## Decision

- The court held Ordinance No. 392-72 invalid to the extent it purported to repeal the authorizing ordinance and cancel the 1971 Cooperation Agreement.
- The court granted declaratory and injunctive relief in favor of CMHA.
- The court ordered the City to comply with the 1971 Cooperation Agreement.

## Legal Principles

- Local governmental action is invalid under the Supremacy Clause when it conflicts with and frustrates the implementation and objectives of a federally authorized and supported public housing program.
- A municipality that voluntarily enters a cooperation agreement within a federal housing framework and accepts related federal benefits may not repudiate the agreement by subsequent ordinance when repudiation would impede federal program execution and impair justified reliance by the housing authority.
- Equitable relief compelling performance is appropriate where repudiation would disrupt a public housing program and reliance-based investments, and damages would not adequately address the harm.

## Conclusion

The court enforced the City’s obligations under a federally connected public housing cooperation agreement, ruling that Cleveland could not nullify its commitments by local ordinance where doing so conflicted with federal housing policy and undermined the ongoing program and CMHA’s reliance.


Cuyahoga Metro. Hous. Auth. v. City of Cleveland, 342 F. Supp. 250 (N.D. Ohio 1972)