Case Type

Non-payment

Housing Type

Other

Court

Civil Court of the City of New York

County

New York County (Manhattan)

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

L&T 307535/22

Petitioner

BROADWAY 69 LLC

Respondent

BRIAN EVINS, JOHN DOE, JANE DOE

Judge

Guthrie, Clinton J.

Decision/Order Date

2026-02-13

Posture

Post-answer Motion by Tenant

Disposition

Motion Granted for Tenant

Winner

Tenant Substantially Won

Synopsis

In this nonpayment proceeding, the court granted the tenant's motion for summary judgment and dismissed the petition. The tenant argued that the landlord was barred from collecting rent under Multiple Dwelling Law § 302 because the building was occupied in violation of its certificate of occupancy. A DOB/ECB violation existed for unlawful use of another apartment for psychic readings during the period for which rent was sought. The court found that MDL § 302 applies strictly, precluding retroactive rent collection during the period of violation, even if the landlord was not at fault and attempted to cure.

Keywords

Illegal Use; Building-Wide Rent Forfeiture; Violation Of Certificate Of Occupancy Bars Rent Collection In All Building Units; Nonpayment Dismissed For Violation of C Of O; MDL § 301; MDL § 302

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