Case Type

Rent Overcharge

Housing Type

Rent Stabilized

Court

Appellate Division, First Department

County

New York County (Manhattan)

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

161448/14

Slip Opinion Number

2026 NY Slip Op 04983

Petitioner

Leisa Aras, et al.

Respondent

B-U Realty Corp., et al.

Judge

Kennedy, Tanya R.; Scarpulla, Saliann; Gesmer, Ellen; Rodriguez, Julio III; Pitt-Burke, Bahaati E.

Decision/Order Date

2026-08-13

Posture

Post-Judgment Motion by Tenant

Disposition

Reversed for Tenant

Winner

Tenant Substantially Won

Synopsis

On remittitur from the Court of Appeals, the Appellate Division First Department addressed the standard for the fraud exception to the four-year lookback rule for rent overcharge claims. The court held that both the common-law standard as refined by Burrows v. 75-25 153rd St. (2025) and the legislature's 2024 statutory 'totality of circumstances' standard for fraudulent deregulation must be applied together, reversing and remanding to Supreme Court.

Keywords

Applying Court of Appeals' Burrows Decision on Fraudulent Deregulation/Overcharge; Supreme Court Directed to Apply Both Common Law Fraud Pleading Standard as Modified by Burrows and the 2024 Legislative "Totality of Circumstances" Standard

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