Case Type

Non-payment

Housing Type

Project Based Section 8

Court

Civil Court of the City of New York

County

Kings County (Brooklyn)

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

L&T 324222-24/KI

Slip Opinion Number

2025 NY Slip Op 52165(U)

Petitioner

1451 Associates LP

Respondent

Lisa Jordan

Judge

Ortiz, Javier E.

Decision/Order Date

2025-12-08

Posture

Post-answer Motion by Tenant

Disposition

Case Dismissed/discontinued

Winner

Tenant Substantially Won

Synopsis

The court vacated a pro se tenant's stipulation of settlement in a non-payment proceeding, finding that over 90% of the stipulated arrears were retroactive lump sum charges under Section 8. The HUD Handbook specifies such charges are not grounds for eviction or a possessory judgment, and housing courts cannot issue money judgments without possession. Additionally, the landlord failed to serve a 30-day rent demand required by the CARES Act for this federally-subsidized dwelling. Consequently, the petition was dismissed without prejudice.

Keywords

Project-based Section 8; HUD Handbook; Retroactive Lump Sum Charges Cannot Be The Basis For Eviction, Cannot Be Sought In Housing Court; Money Judgment Can Only Be Issued Concomitant With Possessory Judgment; Pro Se Stipulation Vacated; CARES Act; 30-Day Rent Demand; Proceeding Dismissed

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