Case Type

Rent Overcharge

Housing Type

Rent Stabilized

Court

Appellate Division, Second Department

County

Kings County (Brooklyn)

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

2024-13192

Slip Opinion Number

2026 NY Slip Op 04748

Petitioner

Nichole Fabo et al.

Respondent

89 Hicks St., LLC

Judge

Iannacci, Angela G., J.P.; Ford, William G.; Ventura, Lourdes M.; Quirk, Susan

Decision/Order Date

2026-07-29

Posture

Post-Answer Motion by Tenant

Disposition

Reversed for Tenant

Winner

Tenant Substantially Won

Synopsis

Tenants in a rent overcharge class action moved to amend their complaint to add a claim that legal regulated rents and resulting overcharges should be calculated using the default formula under RSC § 2522.6(b)(3). The Appellate Division reversed Supreme Court's denial of the amendment, finding the proposed claim not palpably insufficient, and citing a DHCR determination in a similar case as support. The court also clarified that appellate courts are not bound by the law of the case doctrine as applied at the trial court level.

Keywords

Rent Overcharge Class Action; Default Formula for Rent Overcharge Calculations Under RSC § 2522.6(b)(3); Tenants' Motion to Amend Complaint Under CPLR 3025(b) Granted; Appellate Courts not Bound by Law of the Case Doctrine

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