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Another Federal District Court Rules Against CDC Eviction Moratorium

This is the third court to rule that the moratorium is illegal. Two decisions have upheld it.


On Monday, Judge Mark Norris of the Middle District of Tennessee became the third federal judge to issue a decision holding that the Centers for Disease Control nationwide eviction moratorium is illegal. Judge Norris' ruling in Tiger Lily, LLC v. US Department of Housing and Urban Development is very similar to last week's ruling on the same issue in Skyworks v. CDC by a district court in Ohio. Like the Skyworks decision, this one holds that the CDC exceeded the authority granted to it by Congress under 42 U.S.C. Section 264(a), which gives the agency the power to "make and enforce such regulations as in [the Surgeon General's] judgment are necessary to prevent the introduction, transmission, or spread of communicable diseases from foreign countries into the States or possessions, or from one State or possession into any other State or possession." The law goes on to say that "[f]or purposes of carrying out and enforcing such regulations, the Surgeon General may provide for such inspection, fumigation, disinfection, sanitation, pest extermination, destruction of animals or articles found to be so infected or contaminated as to be sources of dangerous infection to human beings, and other measures, as in his judgment may be necessary."

Like the judge in Skyworks, Judge Norris concludes that this listing of examples limits the range of measures the CDC may enact:

Plaintiffs contend the CDC Director is limited to the types of measures to be undertaken…. Defendants contend she is not…. Therein lies the rub. Plaintiffs' interpretation is the more reasonable. If the Director were not limited in his or her authority, why list any specific examples of measures within that authority? Why not simply provide the Director "is authorized to make and enforce such regulations as in [her] judgment are necessary to prevent the introduction, transmission, or spread of communicable diseases."? In other words, Defendants' theory renders the limitations of the statute—e.g. inspection, fumigation, disinfection, sanitation, pest extermination, destruction of animals, or articles to be so infected or contaminated—superfluous or surplusage….

And, like the Skyworks ruling, Judge Norris concludes that allowing the CDC to use this statute to impose an eviction moratorium would give it virtually unlimited power to suppress any activity of any kind, thereby violating the nondelegation doctrine, which limits the extent to which Congress can delegate its lawmaking power to executive agencies. That, in turn strengthens the case for giving the statute a narrower reading, under the longstanding rule that courts should, where possible, interpret federal laws in ways that avoid raising constitutional problems:

The statute before this Court sets forth a narrow list of measures which may be undertaken to make and enforce regulations necessary to prevent the spread of disease. The statute authorizes the Director to undertake certain specifically enumerated acts "and other measures, as in [her] judgment may be necessary." 42 U.S.C. § 264(a). But those "other measures" are limited by the specific examples listed. They provide the intelligible principle without which Congress' delegation of authority in this instance would be too broad to withstand Constitutional scrutiny… To ignore them creates surplusage which is also to be avoided.

It would not be reasonable had Congress delegated such broad authority nor could it constitutionally have done so. The CDC was given broad authority to make and enforce regulations, and the statute specifically identifies the measures to be taken. To hold otherwise would be to construe the statute so broadly as to grant this administrative agency unfettered power to prohibit or mandate anything, which would ignore the separation of powers and violate the non-delegation doctrine….

I discussed the nondelegation issue in greater detail in my very first post on the CDC moratorium back in September, when the order was adopted by Trump administration. It has since been reinstated by Biden after it had expired.

We now have three district court rulings striking down the CDC order, and two upholding it. I analyzed the earlier decisions here and here. It is likely that the legal battle over this issue will continue in the appellate courts - especially if, as I think likely, the Biden administration extends the eviction moratorium past its current March 31 deadline. As I noted in my last post on this issue, it is possible that the litigation over these questions will divide judges and legal commentators along ideological lines. So far, all three judges who ruled against the CDC (including, now, Judge Norris) are conservative Trump appointees; though so is one of the two judges who ruled in its favor. However, for reasons I noted here, liberals have good reason to be concerned about the dangerous precedent a ruling in favor of the CDC could set:

[B]efore concluding that the CDC order is legitimate, I would urge liberals to consider whether they really want the next Republican administration to have the authority to suppress virtually any activity of any kind, so long as the CDC can assert that doing so would reduce the spread of disease even in a small way (and doesn't have to prove that it will actually do so). Do you really want the likes of Trump, Ted Cruz, or Josh Hawley to have that kind of power?

Those who think the CDC can be trusted to wield such sweeping power purely based on "scientific" considerations uninfluenced by political pressure from the White House would do well to consider all the ways in which it yielded to pressure from Trump during the Covid pandemic. Moreover, there is no such thing as a purely scientific way to wield the power to shut down virtually any activity of any kind. Any such decision relies on moral, economic, and political considerations, not just technical scientific ones.

Law Professor Lindsey Wiley, a leading academic expert on public health law worries that the reasoning adopted in Skyworks and Tiger Lily could potentially lead courts to invalidate the Biden administration's order requiring the wearing of masks on various types of interstate transportation, which also relies on Section 264(a) for authorization.

I think this is unlikely because the focus on transportation is much more closely related to the purpose of preventing the "spread of communicable diseases from… from one State or possession into any other State or possession." In addition, limiting it to transportation may fall into the category of promoting the "sanitation" of "articles" that facilitate the spread of disease across state lines. In this case, the relevant "articles" would be seats and air spaces on buses, airplanes, and other modes of transportation covered by the mask order. These distinctions may be the reason why Biden's advisers concluded (correctly, in my view) that he did not have the power to order a general nationwide mask order, but could impose a much narrower one focused on transportation.

That said, if the distinctions I drew between the mask order and the eviction moratorium turn out to be wrong, I am more than happy to bite the bullet. Saving the mask mandate isn't worth the awful price of giving the executive branch virtually unlimited power to suppress any activity it wants. That's especially true in light of the fact that some 90% of Americans were routinely wearing masks by October 2020, well before Biden issued the mask order, and airlines, bus companies, and other interstate transportation providers also routinely required passengers to wear masks. It is, therefore, unlikely that that Biden order is achieving much beyond the mask-wearing that existed already. If an interstate transportation mask mandate really is necessary for some reason, Congress could enact one.

NOTE: The plaintiffs in some of the lawsuits against the eviction moratorium, including the Skyworks case, are represented by the Pacific Legal Foundation, where my wife works. I myself have played a minor (unpaid) role in advising PLF on this litigation.


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48 responses to “Another Federal District Court Rules Against CDC Eviction Moratorium

  1. It would not be reasonable had Congress delegated such broad authority nor could it constitutionally have done so.

    Far broader measures would have been reasonable had Covid19 proved more deadly—and more uniformly deadly, and more contagious among the population—than smallpox. For a pandemic capable of killing 50% of the entire population, forced detention for defiance of even draconian social distancing rules—or mandatory masking and self-quarantines—would have been judged utterly reasonable by nearly everyone. So the debate cannot be about constitutional limits in the abstract.

    The argument that it is about a universal need to limit at some point every legitimately-granted power is self-contradictory. The notion of necessary and proper means is defined by ability of chosen means to accomplish the legitimate ends sought by the delegated power.

    It cannot be that some limit to means must always be in place to assure that those means fall short of full accomplishment of legitimate ends. Specifically prohibited means aside, it is not possible to define any limits to means except in reference to stopping them short of full accomplishment of the ends sought. Who could say whether a means had been limited at all, if it fully accomplished its objective every time? So the notion of a universal limit to be applied alike to every delegated means cannot be anything but a negation of the Necessary and Proper clause.

    1. "The argument that it is about a universal need to limit at some point every legitimately-granted power is self-contradictory."

      Your contrary argument is, apparently, that a Constitution of enumerated powers and explicit limits actually created an omnipotent government, because otherwise at some hypothetical point it might meet a challenge it was unequal to.

      That doesn't just render the language of 42 U.S.C. § 264(a) surplusage, it renders basically the entire Constitution surplusage, by creating a general principle that overrides the whole document.

      1. The Constitution isn't a suicide pact either though.

        We expect our govt to meet any/all disaster scenarios (e.g. killer astreroids, zombies, continential floods [this one might actually happen later this century], nuclear war, etc.).

        Our national govt is the only entity that has the infrastructure (i.e. command structure, communications, finances, etc.), to meet a large scale event.

        Or course we can wonder if our leaders could/would meet the challenge (e.g. Trump's COVID failure).

        1. I genuinely hate that "The Constitution isn't a suicide pact!" line.

          What people who say it really mean is, "The Constitution IS a suicide pact, and as such, we should break it!" They're always advocating some violation of the Constitution when they say it, after all.

          Well, let me say this: The Constitution isn't a suicide pact, in the sense that following it would not be suicidal. But if it's not followed, it's no pact at all, suicide or otherwise. It's just empty verbiage being used as an excuse to rule, not a constitution.

          You want Lathrop's omnipotent Leviathan, either advocate massively amending the Constitution, or stop pretending you want constitutional government. Because we don't have an omnipotent Leviathan constitution.

          1. I want our constitutional govt (maybe with some tweaks), AND I want our govt to not be constrained if faced with a catastrophic event.

            Why is that hard to understand?

            1. Because sane people can't "understand" logical contradictions.

              I understand on a psychological wanting to have your cake AND eat it. I don't understand thinking you can actually do it.

            2. Why do you believe a constrained government cannot also be structured to face any catastrophe?

            3. But as the Supreme Court has asked a few times in recent years:

              What is the limiting principle to that unconstrained power in an emergency?

              Yeah I can see having to take drastic measures for a drastic emergency, but I want to have a clear limiting principle established.

              The US government lost Citizens United because they asserted before the Supreme Court that there was no limiting principle to what they could ban in the interest of making elections "fairer". Books, movies, pamphlets could all be banned.

              The CDC lost it's first eviction moratorium case because they said there was no limiting principle that stopped the CDC from taking action to stop a 'pandemic'. They deserved to lose.

              1. Kazninski, the limiting principles are (and are not) these:

                1. The end sought must be a legitimate constitutional end.

                2. The means chosen must not be specifically ruled out by other provisions of the constitution. For instance, torture is out, because cruel and unusual punishments are specifically prohibited.

                3. The means chosen must be adapted to accomplish the legitimate end. A means incapable of achieving its end is not proper.

                4. Use of the means terminates when the legitimate end has been accomplished.

                5. There is no, "limiting principle," to say use of legitimate means must ever stop short, before legitimate ends to which they are adapted have been achieved.

                6. There is no "limiting principle," to say an otherwise legitimate means must be constrained because using it makes the government too large or too powerful.

        2. "The Constitution isn’t a suicide pact either though."

          The thing to be remembered here is that the Constitution created a federal republic of SOVEREIGN states and hence if civil rights are to be violated for the collective good, it is the states that get to do that.

          This is something that Donald Trump understood -- that police power is held by the states and they (not he) gets to exercise it. I suspect it is also why he didn't implement the insurrection act against the Bitchy Little Marxists.

      2. No, Brett. Limitations in the constitution are not meant as limitations on the effectiveness of enumerated government powers. They are instead limitations on which government powers are allowed, and which are either proscribed, or reserved for exercise by others.

        I get that small-government zealots prefer the notion that each and every government power must be constrained short of full effectiveness. That has nothing to do with the constitution, which says otherwise. It's just your modern ideology, which folks like you try to smuggle into American constitutionalism whenever you can. Unfortunately, there are ideologically inclined judges trying to do the same thing.

        1. "Limitations in the constitution are not meant as limitations on the effectiveness of enumerated government powers. They are instead limitations on which government powers are allowed, and which are either proscribed, or reserved for exercise by others."

          Right. For instance, the portions of the commerce clause limiting its reach to interstate commerce is not meant as a limit on the effectiveness of the federal government's regulation of such commerce, it merely limits such regulation TO interstate commerce.

          Lacking the power to regulate intrastate commerce, or non-commerce, may incidentally impact the effectiveness of interstate commerce regulation, but that's not the purpose for the limitation, it's just an incidental side effect of deliberately placing most things outside the regulatory authority of the federal government.

          1. Brett, we aren't supposed to say this (because we like the outcomes) but a lot of the civil rights cases were wrongly decided. In particular _Katzenbach v. McClung_ (379 U.S. 294 (1964)).

            Now I think that Ollie McClung was an A-hole for only selling takeout to Blacks while having 220 seats for his White customers, but to decide this case on the basis of a Congressional authority to regulate the interstate commerce of catsup was asinine. (I always wondered why McClung didn't just find an in-state source for his catsup, as he had done for his meat.)

            It was this bastardization of the commerce clause which created the problem here -- it was the State of Alabama who ought to have told Ollie to be a nice boy and let all the paying customers in.

            The commerce clause was intended to address specific things which were happening during the Articles of Confederation (e.g. interstate import duties) and the realization that there soon would be landlocked states (with Vermont being admitted in 1791). It was NOT intended to be a blanket license of Congressional authority, no matter how noble the cause.

    2. " For a pandemic capable of killing 50% of the entire population, forced detention for defiance of even draconian social distancing rules—or mandatory masking and self-quarantines—would have been judged utterly reasonable by nearly everyone."

      Well, if the only standard one needed to meet to take authoritarian control over an entire county is merely that it be "judged utterly reasonable by nearly everyone", you'd have instituted a country governed by men, and not by law.

      THAT was a political question fought for more than a millennia in Europe and most decidedly settled to its exact opposite in the founding of the United States. As others noted, its the very reason we even have a written Constitution to begin with.

    3. I suggest aone year moratorium on paying lawyer fees. Due to COVID.

    4. Boader measures might be reasonable for a more deadly/contagious disease - but granting authority to a single Executive Branch agency to make those unilateral determinations would not be.

      We have a legislative process with all it's inherent checks and balances for very good reasons. The claim that we needed 'immediate action' is clearly unjustified. As this latest case clearly demonstrates, the CDC was no faster crafting and implementing their proposals than Congress can be for high-priority legislation.

      The question is not whether the CDC's decision were "good" but whether they were the CDC's decisions to make in the first place.

      To apedad's point, no we do NOT expect our government to meet every conceivable disaster scenario. Once you get rid of that false premise, the rest of the argument collapses.

      1. Nonsense, Rossami. The plan to cope with pandemic emergency was largely in place before COVID-19. The CDC couldn't cope because Trump didn't want the emergency coped with. Trump throttled any attempts to use existing plans and policies if they would expose him to potential blame for getting it wrong. He was an incompetent coward, and he punted when he should have led.

        1. I don't even know how to respond to such absurdly paranoid conspiracy theories.
          Regardless, that has nothing whatsoever to do with the constitutional limits on delegated authority.

        2. "Trump throttled any attempts to use existing plans and policies if they would expose him to potential blame for getting it wrong. He was an incompetent coward"

          I assume just like Bush '43 was for not telling the state & local officials to go fire truck themselves and sending Federal troops in to New Orleans after Katrina. No, both men deserve credit for respecting the authority of incompetent state & local officials.

          Trump gave both NY & CA a hospital ship -- neither used it. Trump handed out PPE from the National Defense stockpile without asking why the states hadn't been prudent enough to have their own. Etc.

          Trump could have declared martial law in NYC and simply had the US Army take over and deal with Covid -- he should be respected for *not* having done that...

    5. But the notion of proportional limits to power depending on the circumstances really means no limit at all. And if it's up to judges to decide what is proportional then you will get a patchwork of decisions.

      At the very least, congress should have to declare martial law and give explicit grants of authority with a explicit expiration.

      Better would be state legislatures granting governors the authority under the states police powers, because the local conditions will differ, and the basis of the states police power is more grounded in the law than thenebulous 'necessary and proper' clause.

    6. "For a pandemic capable of killing 50% of the entire population, forced detention for defiance of even draconian social distancing rules—or mandatory masking and self-quarantines—would have been judged utterly reasonable by nearly everyone."

      No, it wasn't. "Wasn't" as in past tense, as in 33 years ago.

      By 1988 it was known that AIDS was (a) being spread amongst gay men and that it (b) was 100% lethal. While it was known that sodomy spread it, what was not known was the extent to which it was spread by casual contact -- we didn't know.

      Cuba did as you proposed -- from 1986 to 1997, gay men with HIV were locked up in hospital sanatoria. Reagan did *not* do that.

      Bear in mind that we had no idea how fragile the AIDS virus was back then, I'm not even sure we even had identified it yet. But we did know it was 100% lethal to everyone who caught it, and people were scared in a way that they weren't with Covid because (before the drugs) AIDS was a 100% certain death sentence.

      And it's an understatement to say that, outside of certain isolated communities (e.g. San Fransisco, Provincetown, Key West), gay men enjoyed neither the freedoms nor protections they do now -- most of America held them in open contempt.

      Yet even still, it was viewed as too much to lock them all up in concentration camps -- and it helped to have a WW-II generation still around and who remembered when a man named Hitler had done something similar.

      But Stephen, we didn't...

  2. That's especially true in light of the fact that some 90% of Americans were routinely wearing masks by October 2020, well before Biden issued the mask order, and airlines, bus companies, and other interstate transportation providers also routinely required passengers to wear masks. It is, therefore, unlikely that that Biden order is achieving much beyond the mask-wearing that existed already.

    I doubt many who read that would guess from personal experience that compliance was so high. Too many folks were wearing their masks below the nose, for one thing. Among the general public, far too few people had adequate masks for another.

    For the sake of argument, however, accept 90%. Ask yourself which was greater, the quantity of virus among the general population in early March of 2020, or the quantity among them in October? The notion that policy could accomplish little by notably reducing that 10% seems tantamount to insisting the national catastrophe which followed early March—before even 100 deaths had been counted nationwide—could not have happened.

    Given exponential contagion, very small percentages of cases among the population must receive attention proportionate not to their current prevalence, but instead according to the potential for catastrophic spread those cases embody. Arguably, the most beneficial potential for public health measures comes at times when cases are fewest, not when cases are so plentiful that they outstrip available means to reduce case numbers promptly.

    1. The missing middle position is that masking would not have made a difference one way or another, because masking the entire healthy population is an ineffective measure. Since a virus is many times smaller than even an aerosol droplet, and aerosols are not impeded by cloth masks since you can breathe through them, the original recommendation from the health experts was that masks were not going to work.

      Somewhere along the way this cloth masking thing took off, and the population seized on it -- probably merely because of a "we have to do something > masking is something > therefore it must be done" kind of thinking.

      I'm convinced that the initial recommendation to not expect masks to help turned out to be correct. The distribution of infection is nearly random across the country between places with varying masking policies. There's not even a correlation to argue over. It literally made no difference.

    2. Stephen - David M below makes the most important point

      there was virtually zero difference in the infection rates between areas with high compliance with masking and areas with low compliance with masking.

      A tremendous amount of misconceptions about the benefits of mask wearing based on very limited / narrow scope.

      A good example is the common belief among a large segment of pro-maskers is that fully vaccinated individuals should continue to wear masks since they can still transmit the virus. theoritically true, but extremely unlikely.

      1. I am continuing amazed at the resistance of some to simple measures that would give comfort to many of their fellow citizens in a time of great consternation.

        1. Asking people to do nonsensical things to comfort their more ignorant neighbors is one thing. Ordering people to do nonsensical things to comfort their more ignorant neighbors is quite another.

      2. DaveM, Joe_Dallas, I don't listen to pandemic minimizers anymore. You guys listen to nothing, look at nothing, know no evidence you haven't cherry-picked, and ignore > 500,000 fatalities and counting. Your comments above both include outright misinformation. In some obscure way other people can't understand, you guys come at this from some political starting point, and try to fit everything into that. Keep at it if you must. Sensible people stopped listening long ago.

        1. It's not 500,000 fatalities FROM Covid but WITH Covid -- 95% are actually from something else.

          1. "95% are actually from something else."

            Citation needed.

  3. The lockdown of the Democrat Governors is the greatest mistake in history, the biggest fraud heist, the quickest, biggest mass murder. US billionaires scored $1.7 trillion in additional wealth, and those elsewhere, like China, a total of $3.9 trillion. They dropped the world GDP by $4 trillion in 2020. Food prices soared. That killed 100 million people by starvation.

    The American federal judiciary has been a bigger collaborator with this scheme than the German judiciary. German law stated, you cannot confine people who have not committed a crime. The genocidal rampage of Germany violated the law. Only one judge refused to go along, Lothar Kreyssig. The mass murdering US judiciary showed no resistance whatsoever.

  4. I understand and agree with the initial reasoning for the national eviction moratorium.

    However, one year in, everyone should have a grasp on their personal situations and have taken appropriate (remedial) steps.

    I'd say drop the national moratorium but allow (states? counties?), the leeway to address local conditions.

    1. The motives behind the moratorium were comprehensible, but that neither renders the moratorium within the power of the CDC, nor a constitutional means to that understandable end.

      Suppose that the CDC decided that starvation was a threat to health, and issued a shoplifting moratorium against groceries, so that nobody who shoplifted anything edible could be stopped or prosecuted?

      Why bother to have a food stamp program, or distribute surplus cheese, if such a measure was within the the authority of the CDC?

      In reality, I doubt the eviction moratorium would be constitutional even if Congress had enacted it as explicit legislation. It's a massive uncompensated taking, or regulation of entirely intrastate commerce, depending on how you look at it.

      A free people do not have a government capable of things like this, and the Constitution did not establish one.

  5. It's a bad policy to be sure.

    I'd be open to statutory arguments, but constitutionally if we could do price controls for gasoline, we can do this.

    As has been oft said here, not all bad policies are unconstitutional.

    1. Sure, you'd have a constitutional case, if we were talking rent moratoriums on motor homes. (Not a strong one if we were taking constitutional limits on power seriously, but a case.) But rental of fixed assets within a state?

      That's about as classically NOT interstate commerce as it gets. If that's 'interstate commerce' there isn't anything that's NOT interstate commerce.

    2. Gasoline is interstate commerce.

      Individual rents on individual apartments are not.

    3. I like to express it as "You do not have a constitutional right to good government."

      1. But you do have a constitutional right to constitutional government, which is what we're discussing here. The stupidity of this policy has nothing to do with why it's unconstitutional.

  6. I like the hypothetical from a previous thread -- what could the CDC have done with this power during the AIDS epidemic? Sorry, guys, sodomy is too dangerous to allow until the population is vaccinated. And no-questions-asked needle exchanges could be banned or mandated depending on the whim of the president, because IV drugs were the second pillar of AIDS. For the younger readers, in the 1980s having AIDS meant you were a gay man, an IV drug user, or Haitian. The virus has since diversified.

    Next time the flu flies into America it will probably land in a blue state, which can then be quarantined by a red president. (Red president means something different than it did when I was going up. I remember a Mad magazine spoof using creative ellipses to have Nixon or somebody like him saying American would be better off "under a red ruler.")

    I do believe precedent supports an argument that Congress has the authority to impose rent control and similar measures. I don't like that precedent and there might be even 5 votes on the Supreme Court to distinguish an eviction moratorium from _Gonzales v. Raich_ and _Wickard v. Filburn_ without formally overruling them. Maybe. All parties might be better off arguing statutory interpretation and APA rather than risk setting a precedent on the constitutional issue.

    1. Based on the current SCOTUS, I don't think there are 5 votes to sustain an eviction moratorium based on the current case. I don't think there are more than 3 votes to sustain it, to be honest. And maybe less than that.

  7. I found the following article insightful, how the Trump administration firmly got the illegal immigration problem under control at the border. A combination of diplomacy and using the existing laws in place, while simultaneously allowing asylum for those who truly needed it. These policies should be continued by the Biden administration, they are easy, simple, and fair.

  8. A few points

    1) The eviction moratorium has a very teeny weeny effect of the reduction of the spread of Covid, if any effect at all.

    2) This is a taking under 5A - Some argue that not a taking similar to rent control. Yet rent control remains a regulatory taking just the same, just not quite as egregious as a complete eviction moratorium/free rent. (effectively free rent since collection of past due rent rarely exceeds 10%-20% of past due rent)

    1. The whole lockdown was medical quackery. Since the 14th Century, quarantine practice has been to lockdown the infected, not the normal. This was a lawyer catastrophic fraud heist. It enriched our billionaires by $1.7 trillion, and world billionaires by $3.9 trillion. It knocked $4 trillion off the world GDP, and killed 100 million people by starvation. We should come around some time, and bring retribution to the biggest mass murderers in history.

      1. The village of Vo Euganeo in the epicenter of the Italian epidemic tested everyone. They quarantined the infected for 2 weeks, including asymptomatic young people. Epidemic over.

        This is self evident from the 14th Century, lawyer scumbag traitors. These Dem Gov lawyer traitors should be arrested, tried an hour, and executed for mass murder in the basement of the courthouse.

  9. Please correct the venue reference: Judge Norris serves in the Western District of Tennessee, not the Middle District.

  10. The Biden mask order has prompted at lease one airline to weaken it's universal mask mandate by requiring exceptions to people with "well recognized conditions" which make it impossible for a person to wear a mask. As far as I have been unable to determine, there aren't any such conditions.

    1. Well, there aren't any well recognized conditions that require you to have an aardvark by your side, either. But "emotional support animals" were a real thing, and still are to some extent.

  11. Probably when the government can up with the eviction moratorium they thought they were looking at a month or two, not a year. Not creating more homeless people during a pandemic is a good goal, but most landlords need rent every months to cover expenses or they have to sell the property. So it would be better to have more generous unemployment or allow more people to qualify for housing vouchers during a pandemic. If the government is going to require closures then they must compensate the businesses.