## Facts

- Brenda E. Wright and other tenants lived in federally subsidized low-income public housing operated by the City of Roanoke Redevelopment and Housing Authority (RRHA).
- Under the Brooke Amendment to the United States Housing Act of 1937, a low-income family’s rent could not exceed a specified percentage of income; HUD treated “rent” as including a reasonable amount for utilities.
- RRHA used a fixed “utility allowance” credited against tenants’ rent, with tenants paying for utility use exceeding the allowance.
- Tenants alleged RRHA set utility allowances too low, causing overcharges that effectively exceeded the statutory rent ceiling.
- Tenants sued RRHA under 42 U.S.C. § 1983, claiming deprivation of federally secured rights under the Brooke Amendment and HUD regulations.

## Issues

1. Whether public housing tenants may enforce the Brooke Amendment rent ceiling and utility allowance requirements against a local housing authority through an action under 42 U.S.C. § 1983, or whether Congress intended to foreclose such private enforcement in favor of administrative remedies.
2. Whether the Brooke Amendment’s rent limitation, including the requirement of a “reasonable” utility allowance, is sufficiently definite to constitute an enforceable “right” under § 1983 rather than a standard too vague for judicial enforcement.

## Decision

- The Supreme Court reversed the Fourth Circuit and allowed the tenants’ § 1983 action to proceed.
- The Court held that nothing in the Housing Act or Brooke Amendment showed congressional intent to preclude § 1983 enforcement.
- The Court held the Brooke Amendment conferred specific, enforceable rights, including the component requiring a reasonable utility allowance as part of the rent ceiling.
- The case was remanded for further proceedings consistent with recognizing § 1983 enforceability.

## Legal Principles

- A plaintiff may use § 1983 to remedy a state actor’s deprivation of a federal statutory right unless Congress has expressly barred § 1983 or impliedly foreclosed it through a sufficiently comprehensive remedial scheme.
- HUD oversight, administrative sanctions, and local grievance procedures do not necessarily amount to the kind of comprehensive and exclusive enforcement mechanism required to displace § 1983.
- A statutory benefit is enforceable under § 1983 when it is specific and definite enough for courts to apply; a requirement is not unenforceable merely because it uses terms such as “reasonable,” where regulations provide workable standards.
- The Brooke Amendment’s directive that a low-income family “shall pay as rent” no more than a set percentage of income, combined with HUD’s inclusion of reasonable utilities within “rent,” creates an individual entitlement enforceable against a public housing authority.

## Conclusion

The Court held that public housing tenants may sue a local housing authority under § 1983 to enforce the Brooke Amendment’s rent ceiling, including the requirement that utility allowances be reasonable, because the statute confers definite individual rights and Congress did not provide an exclusive remedial scheme that displaces § 1983.


Wright v. Roanoke Redevelopment & Hous. Auth., 479 U.S. 418 (1987)