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Domen Holding Company v. Aranovich
Index No. 00123182/00 (N.Y. Sup. Ct., New York County , Jan. 21, 2005) ; Clearinghouse Number: 55094
Description
Termination Notice Listing Three Disruptive Events Over Five Years Sufficiently Stated Claim for Nuisance
Abstract
The New York Court of Appeals reinstated landlord’s complaint
for eviction based on nuisance against tenant in a rent-stabilized
apartment. Landlord served tenant with a termination notice
alleging a pattern of antisocial behavior and listing three
instances of such behavior. The trial court and appellate division
found that the three instances over five years were insufficient to
establish nuisance under the Rent Stabilization Code. Finding that
the court was not limited to considering the three instances listed
in the notice because the notice alleged that the incidents were
part of a persistent pattern of altercations, the court of appeals
reversed the decision of the appellate division and remanded for
trial. The trial court could also consider the severity and
circumstances of the listed incidents to support landlord’s
claim that tenant was aggressive and prone to violence. On remand,
the trial court granted tenant’s motion to amend her answer
to claim attorney fees. At the initiation of the suit,
tenant’s attorney received Legal Services Corporation (LSC)
funding and was precluded from seeking fees, but by the time of the
remand and motion to amend she was no longer LSC-funded. Landlord
claimed prejudice from the one-year delay and said that landlord
might have followed a different procedural course in the action had
the claim been made earlier. The court found this claim of harm too
speculative. The parties subsequently settled the eviction action.
