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

570249/23

Slip Opinion Number

2025 NY Slip Op 51649(U)

Petitioner

Jacin Investors Corporation, N.V.; Jacin Investors LLC

Respondent

Charlotte Von Vogt

Judge

Tisch, J.P.; Perez, J.; Alpert, J.

Decision/Order Date

2025-10-22

Posture

Other

Disposition

Other

Winner

Landlord Substantially Won

Synopsis

In this holdover proceeding, the Appellate Term reversed the lower court's dismissal of the landlord's petition and ordered a new trial. The landlord sought to recover possession, arguing the apartment became deregulated after a rent-controlled tenant vacated, due to vacancy increases and individual apartment improvements (IAIs). The Civil Court dismissed, citing the landlord's failure to register the apartment as deregulated or stabilized. The Appellate Term held that regulatory status derives from statute, not registration errors or estoppel. The matter is remanded to evaluate the landlord's IAI evidence and the "first rent" legality, as no statute of limitations bars determining an apartment's regulatory status.

Keywords

Deregulation; Rent Control; Rent Stabilization; First Rent; Regulatory Status Determined By Statute, Not Waiver; IAIs

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