Case Type
Holdover-Lease Expiration
Housing Type
Other
Court
Civil Court of the City of New York
County
Queens County (Queens)
L&T / Index / Case / Docket / Clerk's Number
LT-312659-25/QU
Petitioner
TANYA HOBSON-WILLIAMS, Article 81 Guardian of the Person and Property of LUCILLE JENKINS, by and on behalf of LUCILLE JENKINS
Respondent
BOBBY DUCKER; "JOHN" "DOE"; "JANE" "DOE"
Judge
Bryan, David J.
Decision/Order Date
2026-04-16
Posture
Other
Disposition
Case Dismissed/discontinued
Winner
Tenant Substantially Won
Synopsis
The Civil Court sua sponte dismissed a holdover action initiated by the landlord. The court found that the landlord failed to comply with the Good Cause Eviction Law (GCEL) notice requirements by not including the necessary small landlord disclosure under RPL §231-c and RPL §214(1) in the predicate notice. The court held that a defective GCEL notice is unamendable and constitutes a failure to meet a condition precedent for a holdover action. Consequently, the action was dismissed without prejudice, allowing the landlord to commence a new action after correcting the defect.
Keywords
GCEL Notice Requirements
Recommended Citation
"Jenkins v. Ducker" (2026). All Decisions. 2178.
https://ir.lawnet.fordham.edu/housing_court_all/2178
