that its conduct had a “manifest relationship” to the allocation of housing funds in the federal program “and is justifiable on the ground that it is necessary” to that governmental entity’s “exercise of its funding responsibilities.” Id. This approach is sound. It is also in accord with the standards other circuits have developed for the defense available to municipalities for disparate impact claims under the Fair Housing Act. See Huntington Branch, NAACP v. Town of Huntington, 844 F.2d 926, 936 (2d Cir.1988), aff'd in part, 488 U.S. 15, 109 S.Ct. 276, 102 L.Ed.2d 180 (1988) (per curiam) (recognizing the defense of “a legitimate, bona fide governmental interest”); Resident Advisory Bd. v. Rizzo, 564 F.2d at 149 (same); Langkis v. Abington Hous. Auth., 207 F.3d 43, 51 (1st Cir.2000) (<HOLDING>). In the TEFRA context, a municipality may
holding that before a duty can be imposed there must be a relationship between the parties and the harm must have been foreseeable holding that there must be a legitimate and substantial goal of the measure in question holding that generally the question of waiver and estoppel is a question of fact holding it is a question of fact holding that a question of prejudice goes directly to the question of standing therefore the prejudice issue must be reached before addressing the merits