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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Liggett v. Lew Realty LLC, 42 N.Y.3d 415 (2024)

Citation
Liggett v. Lew Realty LLC, 42 N.Y.3d 415 (2024)
Parent Document
Liggett v. Lew Realty LLC, 42 N.Y.3d 415 (2024)
Jurisdiction
New York (state)
Effective Date
2024-06-20

Full Text

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The Appellate Division reversed and dismissed the complaint (211 AD3d 473 [1st Dept 2022]). Relying on Kent v Bedford Apts. Co. (237 AD2d 140 [1st Dept 1997]), the Court concluded that although an agreement by a tenant to waive the benefit of{**42 NY3d at 420} any provision of the rent control law is void, this protection did not apply to McKinney because he was not an established tenant when he signed the stipulation. The Appellate Division also concluded that because Liggett's claim implicates how rents are set, it is akin to an FMRA and therefore barred by the statute of limitations (see 9 NYCRR 2522.3 [c]). Two Justices dissented, concluding that the stipulation is void because it undermines the statutory process for setting initial regulated rents by ensuring McKinney would have no incentive to challenge the higher legal rent, and by requiring him to affirmatively waive his right to file an FMRA. We now reverse. II.