Case Type

Holdover-Lease Expiration

Housing Type

Rent Stabilized

Court

SUPREME COURT, APPELLATE TERM, FIRST DEPARTMENT

County

New York County (Manhattan)

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

570795/25

Slip Opinion Number

2025 NY Slip Op 51470(U)

Petitioner

First NY LLC

Respondent

Greg Marshall

Judge

Brigantti, Tisch, James

Decision/Order Date

2025-09-18

Posture

Other

Disposition

Motion Granted for Landlord

Winner

Landlord Substantially Won

Synopsis

The Appellate Term, First Department, reversed a Civil Court order, reinstating the landlord's holdover petition which sought possession for building demolition. The tenant asserted a waiver defense, arguing the landlord's acceptance of rent payments after serving a nonrenewal notice and during the "window period" vitiated the notice. The court held that the landlord's acceptance of rent, while the demolition application was pending with DHCR and undergoing judicial review, and in accordance with DHCR policy, did not evince an intent to waive the nonrenewal notice. The matter was remanded for further proceedings on the landlord's motion for summary judgment of possession.

Keywords

Demolition of Building Approved by DHCR; Window Period Defense; Vitiation/Waiver of Predicate Notice Based on Acceptance of Rent; Acceptance of Rent under Circumstances did not Indicate Landlord’s Waiver

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