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Facts: Ignoring repeated written warnings, a resident continued to smoke in her Section 8 unit and allow her guests to do likewise. And while the multiple complaints from neighbors about her screaming did little to gain the owner’s affections, the last straw was her arrest for attacking a police officer. After a hearing, the PHA concluded that there were grounds to evict her for engaging in violent criminal activity and repeatedly violating the “Smoke-Free Community” addendum of her lease. The resident appealed.