Case Type

Non-payment

Housing Type

Project Based Section 8

Court

Civil Court of the City of New York

County

Bronx County (Bronx)

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

LT-325234-23/BX

Petitioner

Clinton Arms Associates

Respondent

Franncisca E. Gonzalez, Gelde R. Fernandez

Judge

Hassan, Amira

Decision/Order Date

2025-10-02

Posture

Post-answer Motion by Tenant

Disposition

Case Dismissed/discontinued

Winner

Tenant Substantially Won

Synopsis

The court granted the tenant's motion for summary judgment, dismissing the landlord's nonpayment petition. The landlord sought market rent after purporting to terminate the tenant's HUD Project-Based Section 8 subsidy. However, the landlord failed to demonstrate compliance with HUD Handbook regulations for recertification and subsidy termination. Specifically, the recertification and termination notices lacked required information, proof of proper service (including attempted personal delivery for termination), and timely issuance. The court found that deficient recertification notices, which did not state the exact market rent, preclude a nonpayment proceeding. No question of fact existed regarding the landlord's non-compliance, necessitating dismissal.

Keywords

HUD Project-based Section 8; Nonpay Dismissed Because Landlord/Managment Office Failed to Follow HUD Regulations Prior to Terminating the Subsidy and Charging “Market” Rent; Landlord Must Attempt to Serve Three Notices to Tenant Regarding Recertification by Personal Service Before the Notices May be Served by First-Class Mail

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