Housing Authority of the County of Salt Lake v. Snyder

Summary

The Utah Supreme Court considered whether a district court had subject matter jurisdiction over a public housing authority's unlawful detainer action against a tenant. The court held that the Housing Authority failed to exhaust the required administrative grievance procedure because its lease did not properly incorporate the applicable exemption for evictions involving threats to the health or safety of housing authority employees. The court vacated the district court's ruling and remanded with instructions to dismiss the unlawful detainer action.

Holdings

1. A public housing agency receiving federal assistance must provide the tenant with the federally required administrative grievance process unless a valid statutory and regulatory exemption applies.
2. The Housing Authority did not validly incorporate its grievance procedure or its employee-safety exemption into Snyder's lease because the lease lacked a clear and unequivocal reference to those provisions.
3. Because the Housing Authority failed to exhaust the required administrative grievance process, it had no right to seek relief in district court, and the district court lacked subject matter jurisdiction over the unlawful detainer action.

Questions Presented

1. Whether the Housing Authority was required to provide Snyder with an administrative grievance hearing before terminating his public-housing tenancy and pursuing an unlawful detainer action.
2. Whether the Housing Authority validly incorporated its exemption for employee-safety-related evictions into Snyder's lease.
3. Whether the Housing Authority's failure to exhaust the administrative grievance process deprived the district court of subject matter jurisdiction.

Disposition

vacated