Case Type

Holdover-Nuisance

Housing Type

Market Rate

Court

Civil Court of the City of New York

County

New York County (Manhattan)

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

LT-302801-25/NY

Slip Opinion Number

2025 NY Slip Op 34136(U)

Petitioner

EQR-228 WEST 71st LLC

Respondent

LASHAWN FORD

Judge

Ferdinand, Tracy E.

Decision/Order Date

2025-11-06

Posture

Post-answer Motion by Tenant

Disposition

Motion Granted for Tenant

Winner

Tenant Substantially Won

Synopsis

In this holdover proceeding alleging nuisance, the tenant moved for summary judgment, asserting the landlord failed to state a cause of action by not marking the specific good cause ground on the required GCEL notice, despite acknowledging the premises was subject to GCEL. The landlord argued GCEL applied only to non-renewal cases, not to terminations based on conduct. The court disagreed, holding that GCEL applies to all tenants in covered housing accommodations irrespective of lease expiration or tenancy type. Since the landlord failed to specify the applicable good cause basis in the GCEL notice, the tenant's motion for summary judgment was granted, and the proceeding was dismissed.

Keywords

GCEL; Landlord Must State Grounds For Eviction; GCEL Applies To All Tenants In Covered Housing Accommodations; RPL § 211

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