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Question: Brenda Laramore receives federal assistance pursuant to Section Eight of the United States Housing Act. "Section Eight is a federal program designed to assist the elderly, low income, and disabled pay rent for privately owned housing." The assistance generally comes in the form of a voucher the recipient can use to pay a portion of his or her rent. On October 21, 2002, Laramore telephoned Ritchie, the company responsible for managing the apartment in question, to request an application for a lease. The woman who took the call initially told Laramore the apartment was available to rent. After Laramore informed her she intended to use a Section 8 voucher to pay a portion of the rent, however, the woman told Laramore the apartment was not available to persons using Section 8 vouchers. On February 21, 2003, Laramore fi led suit claiming that Ritchie violated ECOA by denying her a rental application because she receives public assistance. Ritchie moved to dismiss the complaint on the ground that a rental application is not a credit transaction under ECOA. The district court agreed with Ritchie and dismissed the suit. Laramore appealed. Did Ritchie violate ECOA? Should ECOA apply to rental applications?

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