Case Type

Holdover-Lease Expiration

Housing Type

Rent Stabilized

Court

Civil Court of the City of New York

County

New York County (Manhattan)

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

LT-321396-24/NY

Petitioner

SAN-DAR ASSOCIATES

Respondent

NORMA PALIN, JOHN DOE, JANE DOE

Judge

Vendzules, Jason P.

Decision/Order Date

2026-05-28

Posture

Other

Disposition

Judgment for Landlord

Winner

Landlord Substantially Won

Synopsis

In a GCEL holdover proceeding, the court found for the landlord on two grounds of good cause: nonpayment of rent and tenant's repeated refusal to allow access for repairs to water- and fire-damaged floors despite multiple relocation offers. The court held that GCEL nonpayment holdovers do not require a detailed rent accounting in the predicate notice, that GCEL provides no pre-filing opportunity to cure unlike nonpayment proceedings, and that RPL § 235-e[d] does not apply to GCEL holdovers. Tenant's warranty of habitability defenses failed for lack of evidence.

Keywords

Good Cause Eviction Law; Nonpayment Of Rent As Good Cause For Eviction; RPL § 216[1][a][i]; Failure To Provide Access As Good Cause For Eviction; RPL § 216[1][f]; Detailed Rent Accounting Not Required In GCEL Nonpayment Holdover; Opportunity To Cure; RPL § 216(3); RPAPL § 751; RPL § 235-e[d] Not Applicable to GCEL Nonpayment Holdover; Warranty Of Habitability

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