Dallas Housing Authority v. Williams
584 S.W.3d 196 (Tex. App. 2019)
Quick Take
Dallas Housing Authority v. Williams has been cited 38 times — a moderately influential decision in Landlord-Tenant law. Its citation status is "good law," meaning courts continue to follow and affirm this ruling — it remains authoritative.
How to Use This Case
When to cite:
This case has good-law status and is regularly cited in Landlord-Tenant arguments. It's appropriate to cite when you need authority on Due process in public housing or Dual compliance requirement.
Key arguments it supports:
- Public housing authorities must comply with both federal due process and state eviction procedures
- Federal administrative hearing rights cannot be bypassed through state court forcible detainer actions
- Notice of termination in public housing must specify the grounds for lease termination
Court level & jurisdiction:
As a Texas Court of Appeals, 5th District decision, this ruling is binding within its circuit and persuasive in other jurisdictions.
Summary
The court addressed the intersection of federal housing law and Texas eviction procedures. The court held that public housing authorities must comply with both federal due process requirements and Texas Property Code eviction procedures. A housing authority cannot circumvent federal hearing rights by simply filing a state court forcible detainer action.
The court emphasized that tenants in subsidized housing have property interests protected by due process and that adequate notice must include the specific grounds for termination.
Key Holdings
- 1Public housing authorities must comply with both federal due process and state eviction procedures
- 2Federal administrative hearing rights cannot be bypassed through state court forcible detainer actions
- 3Notice of termination in public housing must specify the grounds for lease termination
Why This Case Matters
Important for legal aid practitioners defending tenants in subsidized housing from eviction, establishing dual compliance requirements for housing authorities.
Facts
Dallas Housing Authority filed forcible detainer action to evict tenant from public housing unit. Tenant had not been afforded the federal administrative hearing required under HUD regulations. Housing authority argued state court proceedings satisfied due process.
Legal Principles
Statutes Interpreted
- Tex. Prop. Code § 24.005
- 42 U.S.C. § 1437d(l)
Related Cases
Singh v. Oak Creek Management
612 S.W.3d 108 (Tex. App. 2020)
The court addressed the requirements for a valid notice to vacate under Texas Property Code § 24.005 prior to filing a forcible detainer action. The court held that the notice must strictly comply with statutory requirements, including identifying the property, stating the landlord's demand, and providing the required time period for compliance.
Hernandez v. Lopez Properties LLC
627 S.W.3d 445 (Tex. App. 2021)
The court addressed a tenant's remedies when a landlord fails to make repairs affecting health and safety. The court held that under Texas Property Code § 92.056, a tenant must follow specific procedural steps — including written notice and reasonable time for repair — before exercising self-help remedies such as repair-and-deduct or lease termination.
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