Adams

BACKGROUND

21 Adams entered into a lease with HomeRise for 1413 Flounder Court, Unit E, San 22 Francisco, 94130 (“Unit E”) in 2013, under a contract with the San Francisco Housing Authority 23 (“SFHA”). Complaint (“Compl.”) [Dkt. No. 1] ¶ 3. She rented the apartment through a Project- 24 Based Voucher (“PBV”) program. Pursuant to the PBV program, HomeRise received monthly 25 payments of federal funds (called Housing Assistance Payments, or “HAP”) from SFHA so that it 26 27 could subsidize rental units to low-income tenants. Id. ¶¶ 16-18, 32. Taking the allegations of the Complaint as true, Adams experienced numerous habitability issues while living in Unit E until she evacuated it in November 2021. She claims that she reported these issues to HomeRise and that HomeRise failed to remedy them. Id. ¶¶ 44-49. For example, in 2018, Adams noticed what appeared to be mold growing on her living room ceiling. Id. ¶ 44. Also in 2018, Adams noticed that the carpet in Unit E was torn; at one point, she tripped on the carpet and broke her tooth. Id. ¶¶ 46-47. In 2020 the heater in her unit stopped working, causing Adams to purchase and use a space…