Case Type

Holdover-Non-primary Residence

Housing Type

Rent Controlled

Court

Supreme Court, Appellate Term, First Department

County

New York County (Manhattan)

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

571276/25

Slip Opinion Number

2025 NY Slip Op 52043(U)

Petitioner

957 Park Avenue LLC

Respondent

Francisco Ordonez

Judge

Brigantti, Perez, Alpert, Stoller, Jack

Decision/Order Date

2025-12-23

Posture

Other

Disposition

Judgment for Landlord

Winner

Landlord Substantially Won

Synopsis

The Appellate Term, First Department, affirmed a Civil Court final judgment awarding possession to the landlord in a holdover summary proceeding. The tenant, claiming succession rights as a non-traditional family member to a deceased rent-controlled tenant, failed to establish the requisite emotional and financial commitment and interdependence. The courts found the relationship was "one-sided," lacking mutual support as required by NY City Rent & Eviction Regs § 2204.6[d]. The decision highlights the high burden on a tenant seeking non-traditional family member succession, noting the trial court's warranted conclusion based on the asymmetric dynamic of the relationship.

Keywords

Succession; Rent Control; Non-traditional Family Member; Respondent Failed to Prove Requisite Emotional Interdependence and Financial Commitment; Failure of Proof that Relationship was More than “One Sided”

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