Q&A: recipient of grant from U.S. Dep't of Housing & Urban Development
Q. Is a HUD grantee required to give a private citizen an electronic copy of a HUD document?
A. Highly unlikely. In 1980, the Supreme Court decided in Forsham v. Harris that recipients of federal grants are not agencies subject to the FOIA, unless the grantee is subject to "extensive, detailed, and virtually day-to-day supervision" by the federal grantor.