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It is, of course, quite common for government officials <br />at various levels to sign certifications of compliance <br />with multiple federal laws when receiving funding. It <br />is worth noting that HUD takes these certifications <br />seriously; when a jurisdiction fails to live up to its <br />certification, HUD has taken enforcement action.32 <br />In many cities Housing and Redevelopment Authorities (HRAs) or Public Housing Agencies <br />(PHAs) operate housing programs. As recipients of federal housing funds, HRAs and PHAs <br />have their own affirmatively furthering obligations. <br />Olmstead Planning <br />The Supreme Court's ruling in Olmstead v. L.C.. held that unjustified segregation of persons <br />with disabilities is a form of discrimination under Title II of the ADA. Therefore, public <br />entities must administer their programs and activities in the most integrated setting <br />appropriate. The State of Minnesota has developed an Olmstead Plan, outlining their <br />proposed actions and strategies for abiding by the Olmstead ruling. <br />What this means for cities: <br />• Cities with PHAs should have an Olmstead plan in place that provides integrated <br />housing for persons with disabilities in housing programs run by the PHA. PHAs <br />may have general preferences, which gives priority to persons with disabilities who <br />are at risk of entering or are transitioning from institutional settings. <br />32 See, for example, United States ex rel. Anti -Discrimination Center v. Westchester County, 495 F.Supp.2d 375 <br />(S.D.N.Y. 2007), in which Westchester was sued under the False Claims Act for signing a certification to HUD that it <br />was affirmatively furthering fair housing when it, among other things, failed to consider race based impediments <br />to fair housing choice. <br />43 <br />