MLR makes a forceful statutory argument. It maintains that since it extended Brown's tenancy for a year after the 2017 retaliatory eviction (which is accurate), it is not required, therefore, to further extend Brown's lease. This argument has some allure—it is literally what the statute says. Brown disagrees however. He argues that this passage relates only to the retaliatory act that triggered the initial non-renewal of the lease, but a new retaliatory act, which Brown alleges in the case, is not covered by Real Property Law § 223-b (2). The court asked the parties to provide case law on the subject. Neither party nor the court located any precedent remotely relevant to the issue.
Without guiding precedent, the court must engage the canons of statutory construction. When a court interprets a statute,{**62 Misc 3d at 280} the paramount rule is that it should construe the law to animate the intention of the legislature. The starting point for discerning that intent is the text (Yatauro v Mangano, 17 NY3d 420, 426 [2011]). Thus, the words of the statute and what those words convey, in context, is what the statute means. Here, without a doubt, section 223-b (2)'s language lets a landlord terminate a tenancy after a one-year extension, even if the tenancy's termination is in retaliation for the tenant's prior protected activity which triggered the required one-year extension in the first place. In other words, after a year goes by, the landlord can act with impunity on the old grudge and rid itself of the tenant.