Tolliver v. Housing Authority of the County of Cook

Court terminated Petitioner's federally subsidized Section 8  housing voucher. Because Petitioner reported zero income and then fluctuating income, Housing Authority was required to, but failed to, conduct interim reexaminations with her every 90 days, under the Voucher Program Administrative Plan. This failure allowed agency's alleged overpayments to Petitioner to unreasonably accumulate over several years, without notice to her. Agency's requirement that Petitioner repay $13,488 in overpayments over 36 months was an overly harsh sanction, effectively a de facto termination of her voucher, and deprived her of due process. (GORDON and REYES, concurring.)