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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

New York City Housing Authority v. Pretto, 8 Misc. 3d 708 (2005)

Citation
New York City Housing Authority v. Pretto, 8 Misc. 3d 708 (2005)
Parent Document
New York City Housing Authority v. Pretto, 8 Misc. 3d 708 (2005)
Jurisdiction
New York (state)
Effective Date
2005-05-05

Other Sections in This Document (23)

Full Text

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In the instant case, this court is asked to apply a one-year statute of limitations to any action commenced under RPAPL 711 (5) and 715 (1). This court believes that a one-year statute of limitations is applicable in any proceeding brought by a landlord to evict a tenant for illegal use. The court notes that, unlike the vast majority of holdover proceedings commenced, a “cause of action” for illegal use is derived from a breach of statute as opposed to a breach of lease. Indeed the instant proceeding was brought, in part, as a statutory violation derived under Real Property Law § 231. While that section does not create the cause of action, it is the impetus to commence a proceeding under the RPAPL. Since the court finds that the instant proceeding by its nature involves the forfeiture of a leasehold as the result of criminal activity, it falls squarely within the purview of CPLR 215 (4) and mandates that the proceeding to evict the tenant be commenced within one year after commission of the alleged illegal act.