Renters are being encouraged not to return to New Orleans.

Though over half of the people of New Orleans before Katrina were renters - none of the federal housing money coming into the area is designated for renters. There is some money going to landlords and developers who at some point may provide some affordable housing to some people - but essentially renters are being left out.

This is an administrative complaint sent to HUD that challenges in detail the refusal of the state to help renters.

Administrative Complaint

Secretary Alphonso Jackson Secretary_Jackson@hud.gov and
Kenneth M. Donohue, Sr., Office of Inspector General Kenneth_M._Donohue@hud.gov
U.S. Department of Housing and Urban Development
451 7th Street S.W., Washington, DC 20410

Re: Challenging the Misuse of Federal Community Development Block Grants
By the State of Louisiana in “Road Home” Expenditures of Federal Funds Because There is No Guarantee of A “Fair Share” for Low and Moderate Income Renters and Homeowners

Dear Secretary Jackson and Inspector General Donohue:

This complaint is submitted on behalf of low and moderate income families of Louisiana by the organizations and individuals listed below. This is filed in order to force the State of Louisiana to follow federal law and the requirements of justice. This complaint is filed to make certain that the low and moderate income families suffering hurricane and flood damage in Louisiana receive their fair share of the public resources, at least 50% of the program funds.

Introduction and Summary

Louisiana is planning to spend more than $10 billion dollars for hurricane relief housing efforts in a way that violates federal law, specifically the requirement that at least 50% of these funds be spent “for persons of low and moderate income.” The low and moderate income homeowners and renters of Louisiana are entitled to at least 50% of these federal funds and the way the program is set up they will not get their fair share.

The State has misleadingly named its programs as “The Road Home Housing Programs” despite the fact that the planned expenditures will not provide a realistic road home for most of the people with low and moderate incomes - renters who are majority of the people of the City of New Orleans and who constitute tens of thousands of other households suffering severe damage along the Gulf Coast and low and moderate income homeowners. This complaint is specifically filed to prevent the planned misuse of federal funds under the Community Development Block Grant (CDBG) program and the supplemental appropriations by Congress by the State of Louisiana.

The Louisiana program does not contain sufficient requirements for notifying the public how the funds are being spent nor any realistic way to hold the State accountable for the misuse of funds until after those funds are misspent. Timely public reporting of what the State is doing will ensure transparency and accountability in the rebuilding process and help make certain that rebuilding funds are being distributed legally across households affected by hurricane damages and that low and moderate income households suffering damage will get a fair share of the proceeds of the program.

HUD has a continuing legal obligation to ensure compliance with the CDBG statutes and the specific statutes passed by Congress in this matter plus HUD has an independent obligation to affirmatively further fair housing.

The failure of the State of Louisiana to follow the law puts the entire $10 billion program in jeopardy. Louisiana knows full well that it is required to provide at least 50% of these $10 billion in federal funds for low and moderate income persons, but has, for reasons not publicly stated, chosen not to create a program that will comply with these legal requirements. The first public draft of the program included an admission of the State’s obligations to provide at least half to low and moderate income households – a declaration missing from the final program. Perhaps the State of Louisiana is relying on HUD or the courts to require Louisiana to follow the law. As a result of our system of checks and balances, it is now the duty of the other branches of government to enforce the integrity of the law and make certain that low and moderate income families in Louisiana receive their fair share of these funds.

Purpose of Community Development Block Grant Funds

The Community Development Block Grant program (CDBG) was specifically created by the U.S. Congress to provide assistance to low and moderate income households. The CDBG federal law states: “The primary objective of this chapter and of the community development program of each grantee under this chapter is the development of viable urban communities, by providing decent housing and a suitable living environment and expanding economic opportunities, principally for persons of low and moderate income.” 42 USC 5301(c).

As such, CDBG grantees are required to use at least 70% of their CDBG funding for the benefit of low and moderate income persons – even in the face of a disaster. See, 42 USC 5304(b)(3)(A), 42 U.S. C. 5321, and 24 CFR 570.484.

In terms of the CDBG allocation relating to Hurricanes Katrina, Wilma, and Rita Congress has stated that at least 50% of the funds must benefit persons of low and moderate income. Pub. L. No. 109-148, 119 Stat. 2680, 2779-80 (2005).

At no point in the Louisiana plan is there a detailed breakdown of precisely how the CDBG funds are going to be spent to meet the legal 50% requirement. Without adequate and timely information and accountability, neither the citizens of Louisiana nor the citizens of the rest of the country can have confidence that this $10 billion is being spent legally or that low and moderate income renters and homeowners will receive their fair share.

Refusal to Provide Adequate Resources for Renters

Despite the fact that 84,000 rental units were destroyed or suffered major damage (41% of the total housing) only 15% of the $10 billion program is to be spent on rental units. Of those funds only 15,000 apartments are scheduled to be affordable housing – about 18% of the pre-disaster rental housing market.

Louisiana admits that of the approximately 204,000 housing units that were either destroyed or suffered major damage 120,000 (59%) were homeownership units and 84,000 (41%) were rental units. Louisiana plans to spend $6.3 billion (61%) of the full $10.4 billion of CDBG supplemental funding directly on homeowner-related programs.

In contrast, Louisiana only proposes to spend $1.5 billion (15%) on affordable housing/rental-related programs. The Road Home will only generate 35,000 new or restored rental units, less than half (35,000 of 84,000) of the destroyed rental market in Louisiana. At most 15,000 apartments are to be affordable housing - about 18% of the total pre-disaster rental housing market. The LIHTC/CDBG “Piggyback” program would provide the following below market rents: 4,000 will be for “extremely low income” (below 30% area median income (AMI); 6,500 will be for “very low income” (below 50% AMI but above 30%); and 4,500 will be for “low income” (below 80% but above 50%).

This is a legally insufficient number, given the widespread acknowledgment that the vast majority of uninhabitable rental units were previously occupied by low-income households.

Louisiana recognizes the need to encourage developers to set-aside a specified number of affordable housing units through the use of LIHTC and CDBG incentives. Unfortunately, Louisiana fails to take the next logical step. Specifically, the proposed incentives alone are insufficient. Louisiana should mandate that when public benefits are provided (i.e. capital subsidies and below-market loans) they be directly linked via other requirements to additional affordable housing programs or assistance that is or may become available (e.g. Project-Based Section 8, or Tenant and/or Project-Based Vouchers); thus ensuring affordability to a wide range of low-income people. This linkage must be required for all future capital housing investments that the State controls, including LIHTC (e.g. requiring X% of units be reserved for extremely low-income households, and Y% be reserved for Section 8 vouchers or Project-Based vouchers.) In addition, the minimal term of affordability should be 20 years for all units built or repaired with these public subsidies.

Many other jurisdictions in Louisiana also receive CDBG funds. Historically most of these funds have been targeted to homeowners. Louisiana is fully aware of these other programs and should design this system of allocating funds to acknowledge that there may be other funds available locally for homeowners and, if so, provide an off set. Louisiana can also, like it does with the LIHTC program, incorporate those efforts into the overall plan and thereby increase the resources going to renters.

Louisiana fails to address the status of the federally-assisted housing stock (e.g. Public Housing, HUD Subsidized Mortgage, Project-Based Section 8, RHS, and LIHTC properties) and what steps are being taken to rehabilitate/reconstruct those units in light of the need for affordable housing. In the supplemental however, Congress did instruct HUD “to preserve all housing within the area…that received project-based assistance.” Pub. L. No. 109-148, 119 Stat. 2680, 2781 (2005). Given the needs of the residents who previously resided at these properties, Road Home must allocate sufficient resources to restore these affected properties. Louisiana should explain how the costs of restoring Louisiana’s pre-hurricane subsidized housing will be met, and allocate CDBG funds (either through the Piggyback program or separately) to fill any gaps. Based on HUD damage estimates it is likely that the amount of CDBG and LIHTC funding needed will be at least $300-$450 million. Moreover, Louisiana should adopt a policy that when applicable CDBG funds expended for a particular development should be directed toward the goal of preserving housing that has received project-based assistance.

Louisiana fails to create homeownership opportunities for low and moderate income renters – one of the legislative goals of the CDBG program and one of the stated goals of all HUD activities.

Louisiana does not explain how the needs of low- and moderate-income homeowners and renters of all income levels will be met, especially low income families with children, and how such families will be prevented from becoming homeless, as HUD specifically required for these funds. See 71 Fed. Reg. 7666, 7669 at 7 (b)(iii) (“Each State must submit to HUD an Action Plan for Disaster Recovery that describes … [t]he grantee’s overall plan for disaster recovery including …[h]ow the State will provide or encourage provision of adequate, flood-resistant housing for all income groups that lived in the disaster impacted areas,” including how it will “prevent low-income individuals and families with children (especially those with incomes below 30 percent of median) from becoming homeless.”). Louisiana also fails to satisfy a related provision requiring that it describe “[t]he effects of the covered disaster, especially in the most impacted areas and populations, and the greatest recovery needs resulting from the covered disaster that have not been addressed by insurance proceeds, other federal assistance, or any other funding source.” 71 Fed. Reg. 7666, 7669 at 7(a).

Monitoring and Compliance

Louisiana must be required to do much more in the implementation and monitoring of its housing programs, specifically in terms of the need to ensure compliance with the federally-mandated CDBG spending requirements. As noted above, generally, CDBG assistance must be allocated in such a way that at least 70% of the funds are directed toward activities that benefit an area’s low to moderate income population (in terms of the CDBG allocation relating to Hurricanes Katrina, Wilma, and Rita Congress has stated that at least 50% of the funds must benefit persons of low and moderate income).

While there is no requirement that all CDBG funds must be directed toward the benefit of low and moderate income households, there is a requirement that at least 50% of the funds reach such households. As a result, it is imperative that Road Home establish reporting mechanisms that monitor the cumulative spending patterns of its programs so low and moderate income renters and homeowners receive their fair share of the resources.

Therefore, given the current structure of the housing, infrastructure and economic development programs and the general assumptions that were made with regard to program funding and program beneficiaries, it is imperative that Road Home establish detailed performance standards, reporting and monitoring routines, and an enforcement strategy to ensure compliance with the above noted CDBG regulations and to ensure that the programs produce the public benefits they were originally intended to generate.

A similar critique was also recently raised by a Louisiana good-government watchdog group, Public Affairs Research Council. The group noted its worries about the use or abuse of the CDBG money. "The state is unprepared quite frankly. We don't have in place the arsenal of oversight mechanisms [to ensure] the state will be a trustworthy steward of these funds," said Jim Brandt of the Public Affairs Research Council.

Congress directed both the state and HUD to report to the Committee on Appropriations quarterly on all uses of funds. Public Law 109-148. The February 13, 2006 Federal Register Notice (FR Vol.71, No. 29, page 7668) establishing the basic operating procedures associated with the supplemental CDBG funds requires each grantee to submit a quarterly performance report until all funds have been expended and all expenditures have been reported)(p 7679, #14b). Each quarterly report must provide information about the uses of funds during the quarter including: project name, activity, location, and CDBG “national objective”; funds budgeted, obligated, drawn down, and expended; source of funding and total amount of any non-CDBG disaster assistance funds; beginning and ending dates of activities; and, performance measures such as numbers of low and moderate income households benefiting. In addition, each performance report must be posted on a web site for public review (Preamble to Notice, p 7668).

The State should provide public monthly reports with clear and current information that tracks income, race, and geography of all program recipients to ensure equity in distribution of resources, and compliance with low- and moderate-income program requirements. The standard CDBG reporting mechanism, called the Grantee Performance Report, or GPR (also know as Report C04PR03 in HUD’s IDIS management information system) routinely collects activity benefit information regarding income category, race, and geography; therefore compliance with this important extra level of detail beyond that called for in the February 13 Notice is not a reporting problem.

It is essential that accurate reporting be provided on a timely basis in order for the people of Louisiana to determine the extent to which they are benefiting and to detect problems with performance in order to quickly secure corrective measures. Beyond web posting, paper monthly reports should be provided to residents who request to receive copies of them. A process should be established for written comments to be received and formally responded to in writing. And, a quarterly public process, such as public hearings or public meetings held at times and places conducive to participation by residents and other low and moderate income people, should be established for officials to hear and respond to oral comments, concerns and suggestions. Jurisdictions and other public bodies should establish affirmative outreach practices to residents in the low and moderate income communities in order to ensure that they know about the reporting and public monitoring process.

Public reporting will ensure transparency and accountability in the rebuilding process and ensure that rebuilding funds are being distributed fairly across households affected by Katrina.

Louisiana has also failed to insure the "expanding economic opportunities, principally for persons of low and moderate income" portion of its obligation under the law. The CDBG statute requires "The primary objective of this chapter and of the community development program of each grantee under this chapter is the development of viable urban communities, by providing decent housing and a suitable living environment and expanding economic opportunities, principally for persons of low and moderate income." 42 USC 5301(c).

Louisiana fails to demonstrate how they are going to comply with Section 3 of the Housing and Urban Development Act of 1968 (12 USC 1701u(3)) and 24 CFR 135.1 which state that CDBG funds… “shall, to the greatest extent feasible, and consistent with existing Federal, State and local laws and regulations, be directed to low- and very low-income persons, particularly those who are recipients of government assistance for housing, and to business concerns which provide economic opportunities to low- and very low-income persons.” The regulations provide further that in the event that there is a contract for services that exceeds $100,000 a priority shall be provided to low and very low income individuals for at least 30% of all new hires. The greatest extent feasible language has been interpreted expansively by HUD so as to focus on the obligation "to the greatest extent feasible" and to avoid validating a recipient's efforts to defy the intent of Section 3 by efforts such as a hiring surge on the last days of a contract or by other means. There is no evidence in the Road Home that Louisiana has considered its Section 3 obligation, made plans to comply or considered how it will monitor and report on compliance with the obligation. Because economic development is very important in moving people out of poverty, Louisiana must be directed to include specific provisions, with appropriate accountability, to make sure that the expanding economic opportunities required by CDBG funds are directed in accordance with law.

Finally, there is serious concern that because Louisiana does not set out clear and enforceable rules and regulations for disclosure and accountability to make sure that low and moderate income persons receive 50% of these funds, the funds may be released so quickly to other households that there will not be 50% of the funds left for low and moderate income persons. Therefore, HUD should require Louisiana to set up procedures to allow an immediate freeze of all expenditures to people who are not low and moderate income if it looks at any point like more than 50% of the proceeds of the program are not going to low and moderate income persons so that the program can be re-formulated at that point to comply with the requirements of law.

Given the lack of oversight, transparency and accountability in the current Louisiana plan, there must be a way to impose a freeze on the outflow of the money when it appears that Louisiana is not going to give low and moderate income persons their fair share.

Fair Housing

One of the express requirements Louisiana must satisfy upon acceptance of the CDBG disaster recovery funds is to affirmatively further fair housing, “which means that it will conduct an analysis to identify impediments to fair housing choice within the state, take appropriate actions to overcome the effects of any impediments through that analysis, and maintain records reflecting the analysis and actions in this regard.” Certification, 71 Fed. Reg. 7671 (Feb. 13, 2006).

In addition to provisions barring discrimination by intent or effect, HUD and states utilizing CDBG funds are also subject to 42 U.S.C. §§ 3608(d), (e), which requires that all programs related to housing be administered “in a manner affirmatively to further” fair housing. This provision imposes “a substantive obligation to promote racial and economic integration” in federal housing programs. Alschuler v. HUD, 686 F.2d 472, 482 (7th Cir. 1982). An agency’s affirmative duty is not merely to refrain from discrimination, but to use federal programs to actively promote the goals of the Fair Housing Act – including, of course, not intentionally or disproportionately excluding African-Americans or other minorities from program participation, and not contributing to the displacement and exclusion of minorities from the Gulf Coast. See NAACP, Boston Chapter v. Sec’y of HUD., 817 F.2d 149, 154-55 (1st Cir. 1987); Anderson v. Alpharetta, 737 F.2d 1530, 1535 (11th Cir. 1984); Langlois v. Abington Hous. Auth., 234 F. Supp. 2d 33, 72 (D. Mass. 2002).

At a minimum, this obligation to affirmatively further fair housing requires HUD and state agencies to consider the effects of housing policy decisions on racial segregation. See, e.g., Shannon v. HUD, 436 F.2d 809, 821-23 (3d Cir. 1970) (an agency cannot meet its affirmative obligations unless it gathers data and considers all relevant racial and socioeconomic factors related to its decision’s effects); Alschuler v. HUD, 686 F.2d 472, 482 (7th Cir. 1982) (same). Certainly, “[t]he absence of any record of fair housing considerations,” Langlois, 234 F. Supp. 2d at 78, runs afoul of these obligations. See also Owens v. Charleston Hous. Auth., 336 F. Supp. 2d 934 (E.D. Mo. 2004), aff'd in part, Charleston Hous. Auth. v. United States Dep't of Agriculture, 419 F.3d 729 (8th Cir.2005).

Louisiana fails to indicate whether it has performed this analysis and/or whether this analysis has been revisited since the hurricanes. Under the circumstances, it is very likely that a new set of impediments to fair housing have arisen since the hurricanes; therefore, Louisiana has an obligation to address how the State will identify and attend to these impediments. In particular, the Road Home must be designed in a way that avoids rules or limits which disproportionately exclude participation by minority groups, the disabled and other protected categories. Louisiana’s fair housing obligations also include, as noted above, the obligation to monitor the racial composition of program participants.

Finally, HUD itself has civil rights and anti-discrimination responsibilities in this area under Executive Order 11063 of Nov. 20, 1962 which imposes compliance and enforcement obligations. See Title 24 of the Code of Federal Regulations, Section 107. HUD is not allowed to release funds to Louisiana unless those responsibilities are met.

Assistance to Homeowners

There are several serious problems in the current plan that disadvantage low and moderate income homeowners in Louisiana and can prevent them from receiving their fair share of the resources of this program.

The first problem in Louisiana’s CDBG plan is the $30,000 penalty imposed against homeowners without insurance.

According to HUD figures this will impose penalties on well over 35,000 Louisiana homeowners who suffered serious damage to their homes, many of whom are low and moderate income. That means the people who actually suffered the most from the serious damages will get less than necessary to rebuild and repair. HUD should insist that Louisiana reformulate this part of the plan.

The scope of this problem is documented by HUD in its recent report on the numbers of homeowners with serious damage and lack of insurance in: U.S. Housing Market Conditions, 1st Quarter Report, “The Impact of Hurricanes Katrina, Rita, and Wilma on the Gulf Coast Housing Stock.”

The HUD report shows that in Orleans Parish, of the 53,747 seriously damaged owner-occupied homes, 34% did not have insurance, and the SBA median cost to repair is $103,955. In St. Bernard, of the 13,376 seriously damaged owner-occupied houses units, 35% did not have insurance for the damage and the SBA median cost to repair is $142,612. In Cameron Parish of the 2,025 seriously damaged owner occupied homes units, 63% did not have insurance and the median SBA cost to repair is $126,657. In Plaquemines Parish, of the 3,722 seriously damaged owner-occupied houses units, 63% did not have insurance for the damage and the SBA median cost to repair is $96,176. In St. Tammany Parish, of the 13,689 seriously damaged owner-occupied houses units, 31% did not have insurance for the damage and the SBA median cost to repair is $87,521. In Jefferson Parish, of the 20,339 seriously damaged owner-occupied houses units, 18% did not have insurance for the damage and the SBA median cost to repair is $67,248. In Vermillion Parish, of the 2,108 seriously damaged owner-occupied houses units, 61% did not have insurance for the damage and the SBA median cost to repair is $55,809.

HUD must require Louisiana to make certain that this requirement does not harm low and moderate income homeowners. This can be done by eliminating or reducing the penalty for low and moderate income homeowners.

The second problem is that Louisiana unjustifiably relies on FEMA to help it figure out who is entitled to homeowner assistance. Homeowner assistance should be available to any homeowner whose home was destroyed or suffered major damage, regardless of whether they successfully navigated the FEMA application process.

Unlike federal CDBG funds, FEMA individual assistance is by law available only to “qualified” immigrants, a restrictive category that excludes many lawfully present immigrants. Many immigrants and citizens alike have not been able to obtain FEMA Individual Assistance because they were unaware of existing programs and/or deadlines. Press reports in the weeks following Hurricane Katrina indicated that literally thousands of Vietnamese and Hondurans bypassed officially-sanctioned shelters in favor of temporary refuges such as the Hong Kong City Mall on Bellaire, where Vietnamese hurricane survivors received free food and shelter from fellow Vietnamese. Other immigrants and citizens with limited English proficiency were unable to fill out the requisite application forms due to the lack of translators at Red Cross shelters and call centers. Still others refrained from applying for FEMA Individual Assistance for fear that receipt of assistance would render them public charges and thus jeopardize their ability to adjust their immigration status in the future. All such individuals appear to be initially ineligible for homeowner assistance under the Louisiana plan.

Homeowner assistance should be available to any homeowner whose home suffered major damage, regardless of his or her particular immigration status. Although “The Road Home” specifies that homeowners who believe they have suffered “major or severe damage, but have not secured FEMA assistance will be able to appeal their eligibility,” we have no idea how this provision will be applied in practice. Moreover, we see no reason why the only option for many immigrant homeowners should be to go through an appeals process. While FEMA registration should be one criterion for screening applicants, the plan should delineate alternative mechanisms by which applicants may demonstrate that their home suffered major damage.

Third, there are concerns that the current plan may force a number of homeowners to finance a sizeable portion of their rebuilding expenses through assistance in the form of loans rather than grants. This will considerably increase the long-term financial burdens that face many homeowners, particularly lower-income homeowners.

Fourth, the very structure of the homeowner housing assistance program does not protect the interests of low and moderate income homeowners in that it is set up as a first-come, first-served program. Such an approach prioritizes people with access to lawyers, accountants, and other professionals who can help the applicant navigate the process quickly in order to pull down money from the program.

Given the lack of reporting on their obligation to reserve at least 50% of this money for low and moderate income persons, all the funds for homeowners could be depleted long before the low and moderate income homeowners get their fair share. Louisiana must be required to create mechanisms and additional services to allow and, if necessary prioritize, low and moderate income homeowners access into the program to guarantee that it follows the law.

Conclusion

For CDBG purposes, low and moderate income households are described in the statute and federal regulations as 80% of the median income for the area where the funds are going. In the New Orleans metro, the 2005 median income, according to HUD’s Office of Policy Development and Research, was $51,000 and four person low and moderate income households had incomes of less than $40,800. The median per capita income is $19,711. Therefore, the low and moderate income group is people with incomes of less than $15,769. It is estimated that, of the Louisiana black residents over the age of 18, that remain displaced, their median household income is $13,329.

Most of the 200,000 plus people who have not returned to New Orleans, or the over 300,000 who have not returned to the metropolitan area, are people who are of low and moderate incomes. The proper and legal use of these funds will allow the working people of New Orleans and other areas damaged by the hurricanes and floods to return home.

In summary, HUD is requested to enforce the law and require Louisiana to follow the law. Specifically that means HUD must:

1) Require that Louisiana set clear and realistic performance standards to ensure that at least 50% of the funds expended benefit persons of low and moderate income;
2) Require that Louisiana establish monthly public reporting on income, race, and geography of all program recipients and monthly reporting of all expenditures on an activity by activity basis under the programs;
3) Require that Louisiana establish procedures to ensure that low and moderate income families, renters and homeowners, are aware of the program and that their applications for assistance are expedited and provided a priority in processing;
4) Require Louisiana to set up procedures to allow an immediate freeze of all expenditures to people who are not low and moderate income if it looks at any point like more than 50% of the proceeds of the program are not going to low and moderate income persons so that the program can be re-formulated at that point to comply with the requirements of law;
5) Require Louisiana to make the other changes outlined above to comply with the requirement that persons of low and moderate income receive their fair share of the resources of these programs;
6) Require that Louisiana comply with the Fair Housing Act and detail how their plan is consistent with the obligations HUD has under Executive Order 11063 of Nov. 20, 1962; and
7) HUD must itself monitor compliance with the CDBG statute, all the Gulf Coast supplemental programs, the Fair Housing Act, and Executive Order 11063 of November 20, 1962. To do this effectively, it must require Louisiana to provide public monthly reports regarding the race, geography, and income of all program recipients and public monthly reports on the expenditures of all funds on an activity by activity basis.

This complaint is submitted by the following individuals, groups and organizations:

Advancement Project
Judith A. Browne
Washington, DC

African American Leadership Council
Mtangulizi Sanyika
New Orleans, LA

Common Ground Collective
Soleil Rodrigue
New Orleans, LA

Hope House
Don Everard
New Orleans, LA

Louisiana NAACP
Dr. Ernest Johnson
Baton Rouge, LA

National Housing Law Project
Catherine M. Bishop
Oakland, CA

National Low Income Housing Coalition
Sheila Crowley
Washington, DC

New Orleans Legal Assistance
Southeast Louisiana Legal Assistance
Mark Moreau and Laura Tuggle
New Orleans, LA

New Orleans Chapter of NAACP
Danatus King
New Orleans, LA

Peoples Hurricane Relief Fund
Kanika Taylor and Malcom Suber
New Orleans, LA

Peoples Organizing Committee
Ishmael Muhammad
New Orleans, LA

The Partnership for Working Families
Sara Zimmerman and Julian Gross
Oakland, CA

United Front for Affordable Housing
C3 – Hands Off Iberville
Elizabeth Cook
New Orleans, LA

William P. Quigley,
Loyola University School of Law
7214 St. Charles Avenue
New Orleans, LA 70118
504.861.5591
Quigley@loyno.edu

Tracie Washington, Esq.
Law Office of Tracie L. Washington, APLC
2606 Dryades Street
New Orleans, Louisiana 70113
504.899.1889
tlwesq@cox.net