Case Type

Holdover-Non-primary Residence

Housing Type

Rent Stabilized

Court

Supreme Court, Appellate Term, First Department

County

New York County (Manhattan)

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

570888/25

Slip Opinion Number

2025 NY Slip Op 51631(U)

Petitioner

138 West 46th Street Realty Co. LLC

Respondent

Bernadette Coen Hunter

Judge

Tisch, Perez, Alpert, Stoller, Jack

Decision/Order Date

2025-10-17

Posture

Post-judgment Motion by Landlord

Disposition

Judgment for Tenant

Winner

Tenant Substantially Won

Synopsis

The Appellate Term affirmed the dismissal of a landlord's holdover petition seeking to evict a rent-stabilized tenant for non-primary residence. The landlord based its claim on the tenant's two-year absence while recovering from a stroke in a rehabilitation facility. The court found the absence excusable for primary residence purposes, supported by evidence of the tenant's discharge plan and return. It further concluded that the landlord was not unfairly surprised by the tenant's medical condition defense, as the petition itself acknowledged the tenant's stroke and need for care, and the tenant's answer had raised the possibility of a reasonable accommodation.

Keywords

Non-Primary Residence Holdover; Excused Absence Due To Stay In Rehabilitation Facility

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