Case Type
Holdover-Licensee
Housing Type
Market Rate
Court
Civil Court of the City of New York
County
Kings County (Brooklyn)
L&T / Index / Case / Docket / Clerk's Number
302419/25
Petitioner
FEDERAL NATIONAL MORTGAGE ASSOCIATION
Respondent
Sheila Goffe, Lashanna Edwin, Doris Edwin, Mrs. Jones, John Doe, Jane Doe
Judge
Slutzky, Elyssa O.
Decision/Order Date
2026-04-09
Posture
Post-answer Motion by Tenant
Disposition
Case Dismissed/discontinued
Winner
Tenant Substantially Won
Synopsis
A landlord commenced a post-foreclosure holdover proceeding and moved to amend the caption to substitute a new owner as petitioner. The tenant cross-moved to dismiss for lack of standing, arguing the proposed new landlord was not the direct purchaser from the foreclosure sale. The court denied the landlord's motion and granted the tenant's cross-motion. It found that the proposed new landlord, being "one-step removed" from the original foreclosure purchaser, lacked standing under RPAPL §713(5) to maintain the proceeding. Consequently, the case was dismissed.
Keywords
Post-Foreclosure Licensee Holdover Under RPAPL § 713(5); New Owner’s Motion to Substitute Petitioner Denied; Respondent’s Cross-Motion to Dismiss Granted Because New Owner/Proposed Petitioner Is Not First Purchaser After Foreclosure
Recommended Citation
"FEDERAL NATIONAL MORTGAGE ASSOCIATION v. Goffe" (2026). All Decisions. 2189.
https://ir.lawnet.fordham.edu/housing_court_all/2189
