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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Hillside Place, LLC v. Shahid, 75 Misc. 3d 35 (2022)

Citation
Hillside Place, LLC v. Shahid, 75 Misc. 3d 35 (2022)
Parent Document
Hillside Place, LLC v. Shahid, 75 Misc. 3d 35 (2022)
Jurisdiction
New York (state)
Effective Date
2022-04-29

Full Text

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In this case, landlord did not wait a prolonged period to apprise tenant of the Casado increases. To the contrary, landlord moved less than a month after Casado was decided to amend its petition to assert the increases (cf. 89-21 153, LLC v Cruz, 70 Misc 3d at 24 [landlord waived right to Casado arrears where it filed its petition seeking those arrears over seven{**75 Misc 3d at 39} years after the Court of Appeals' decision in Casado]). Moreover, Matter of 1437 Carroll involved an appeal from an article 78 proceeding, where the standard of review was limited to whether DHCR's determination was arbitrary and capricious, and without a rational basis in the record (see Matter of 1437 Carroll, LLC, 150 AD3d at 1224; see also CPLR 7803 [3]). Here, in contrast, the Civil Court made no determination as to the merits of the increases, but simply permitted landlord to amend its petition to allege those increases (cf. 89-21 153, LLC v Cruz, 70 Misc 3d at 24-25 [affirming order granting tenants' motion for summary judgment on the ground that landlord and its predecessor had waived the right to seek Casado arrears]). Since the amendment was sought shortly after Casado, we conclude that tenant had sufficient notice of landlord's right to seek Casado increases and was not prejudiced by the amendment.