The Brennan Center for Justice at New York University School of Law submits this brief in support of petitioner-respondent in order to highlight both the New York City Housing Authority’s (“NYCHA’s”) practice of evading its own regulations by pressuring unrepresented tenants to enter into burdensome stipulations moments before administrative hearings and the substantial due process concerns presented by this practice. Due process requires NYCHA to afford tenants an administrative hearing prior to terminating a tenancy but, as demonstrated by the record in this matter, NYCHA instead induces its tenants to waive this important right with no opportunity to consult counsel and while under substantial pressure. Although NYCHA has months to present proposed stipulations to tenants prior to the time of administrative hearings, NYCHA regularly lets the time pass and makes its offers of stipulation at the last second when tenants have no opportunity to consult counsel. Through this practice, NYCHA pressures tenants into accepting stipulations that impose conditions more burdensome than the tenants could otherwise receive.