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

LT-314072-24/NY

Slip Opinion Number

2026 NY Slip Op 31109(U)

Petitioner

191 AUDUBON CORP.

Respondent

DARLIN GOMEZ; JOHN DOE; JANE DOE

Judge

Blinova, Yekaterina

Decision/Order Date

2026-02-06

Posture

Pre-answer Motion by Tenant

Disposition

Case Dismissed/discontinued

Winner

Tenant Substantially Won

Synopsis

Court dismissed nonpayment petition under MDL §§ 301 and 302 because two open DOB violations found uses of the building contrary to the certificate of occupancy. Court reaffirmed the well-established principle that MDL §§ 301-302 violations preclude the owner from collecting rent or maintaining a nonpayment proceeding for all units in the building, not merely the units directly implicated by the violation.

Keywords

MDL § 301; MDL § 302; Certificate Of Occupancy; Occupancy Contrary To CO; DOB Violations; Entire Building Precluded From Collecting Rent; Not Limited To Affected Units

Share

COinS