Williams v. HUD, 2006 WL 2546536 (E.D.N.Y. Sept. 1, 2006) and 2008 WL 5111105 (E.D.N.Y. Dec. 4, 2008). The plaintiff brought suit against HUD, the New York City Housing Authority (NYCHA) and a private business alleging that the business fraudulently and illegally rescinded an offer of employment, and HUD erred in dismissing the plaintiff's administrative complaint, in violation of Section 3. The court granted summary judgment for the defendants as the plaintiff did not have a private right of action to enforce the Section 3 statute. Further, the plaintiff did not show that his failure to be hired was the result of state action as the private business did not become a state actor by virtue of its contract with NYCHA nor did NYCHA exercise coercive power or significant encouragement in the private business’s decision not to hire plaintiff.
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