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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Pusatere v. City of Albany, 185 N.Y.S.3d 350 (2023)

Citation
Pusatere v. City of Albany, 185 N.Y.S.3d 350 (2023)
Parent Document
Pusatere v. City of Albany, 185 N.Y.S.3d 350 (2023)
Jurisdiction
New York (state)
Effective Date
2023-03-02

Full Text

795 chars
Supreme Court held that the Code of the City of Albany §§ 30-327 and 30-328 were barred by conflict preemption because they required a landlord to prove the additional element of "good cause" prior to evicting a tenant, restricted landlords' access to the courts, limited the eviction remedy provided to them in the RPAPL and interfered with their right to increase rent and terminate month-to-month tenancies upon 30 days' notice. As a result of the direct conflicts between the Code of the City of Albany §§ 30-327 and 30-328 and the relevant state law — RPAPL 711 (1) and Real Property Law §§ 226-c and 228 — the court nullified those sections. Because the court found that the remainder of Local Law F was intended to support the nullified sections, it nullified the entirety of Local Law F.