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Facts: Owners of a project-based Section 8 site sued HUD to challenge regulations that provide standards for “decent, safe, and sanitary” low-income housing. Under Section 8 of the Housing Act of 1937, HUD provides housing assistance through both “project-based assistance,” where HUD enters into contracts with property owners to subsidize designated dwellings, and “tenant-based assistance,” where HUD gives vouchers for tenant-selected dwellings.