Case Type

Other

Housing Type

Rent Stabilized

Court

Court of Appeals

County

New York County (Manhattan)

L&T / Index / Case / Docket / Clerk's Number

26

Slip Opinion Number

2025 NY Slip Op 01672

Petitioner

LL 410 East 78th Street LLC, Appellant

Respondent

Division of Housing and Community Renewal, Respondent

Judge

SINGAS, J.

Decision/Order Date

2025-03-20

Posture

Other

Disposition

Other

Winner

Other

Synopsis

The Court of Appeals affirmed the denial of a landlord's Article 78 petition seeking to annul DHCR's decision to deny its application to amend rent registrations. The landlord claimed the registrations were mistakenly filed, as the unit was permanently exempt due to high-rent vacancy. However, DHCR denied the application, interpreting RSC § 2528.3(c) to permit only ministerial, not substantive, amendments. The court found this interpretation to be rational, as it protects tenants from fraud, preserves agency resources, and reserves complex disputes over regulatory status for adversarial proceedings rather than preemptive amendment applications. The court held that DHCR's action was not arbitrary or capricious.

Keywords

DHCR Properly Denied Landlord's Application to Amend Rent Registration History Under RSC § 2528.3(c); Amendment of Registration History Allowed Only for Ministerial, not Substantive Issues

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