Case Type

Holdover-Other

Housing Type

HDFC

Court

Civil Court of the City of New York

County

Kings County (Brooklyn)

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

LT-306938-25/KI

Slip Opinion Number

2026 NY Slip Op 32213(U)

Petitioner

141 MacDonough Street Housing Development Fund Corporation

Respondent

Tawanda Rhodes-Wiggins

Judge

Sulay K. Grant, J.

Decision/Order Date

2026-08-18

Posture

Pre-Answer Motion by Tenant

Disposition

Case Dismissed/discontinued

Winner

Tenant Substantially Won

Synopsis

Companion case to LT-306940-25/KI—same building, same HDFC, same judge (Grant, J.). The same Grimmet analysis applies. The notice of termination is identically deficient, alleging only 'failed to pay rent' without specifying the period or arrears amount. The same predicate notice inadequacy compels dismissal. Additionally, 34 HPD violations exist against the premises (29 pre-notice) including 3 rent-impairing violations that have not been certified as corrected, which are relevant to the adequacy of notice because uncorrected rent-impairing violations could implicate an MDL §302-a abatement defense. Proceeding dismissed.

Keywords

HDFC; Private Housing Finance Law Article XI; General Business Law § 352-eeee; Government Entwinement; Constitutional Due Process; Grimmet Test; Good Cause Required for Eviction; 512 East 11th Street HDFC v Grimmet; Predicate Notice Must Specify Months of Nonpayment and Amount Owed; Vague Predicate Notice Insufficient

Download

Takedown Policy

Share

COinS