GARDEN SPIRES URBAN RENEWAL, LP VS. OLIVE YANFORD (LT-013235-19, ESSEX COUNTY AND STATEWIDE)

CourtNew Jersey Superior Court Appellate Division
DecidedNovember 5, 2020
DocketA-5382-18T1
StatusUnpublished

This text of GARDEN SPIRES URBAN RENEWAL, LP VS. OLIVE YANFORD (LT-013235-19, ESSEX COUNTY AND STATEWIDE) (GARDEN SPIRES URBAN RENEWAL, LP VS. OLIVE YANFORD (LT-013235-19, ESSEX COUNTY AND STATEWIDE)) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
GARDEN SPIRES URBAN RENEWAL, LP VS. OLIVE YANFORD (LT-013235-19, ESSEX COUNTY AND STATEWIDE), (N.J. Ct. App. 2020).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-5382-18T1

GARDEN SPIRES URBAN RENEWAL, LP

Plaintiff-Respondent,

v.

OLIVE YANFORD,

Defendant-Appellant. _________________________

Argued October 22, 2020 – Decided November 5, 2020

Before Judges Mawla and Natali.

On appeal from the Superior Court of New Jersey, Law Division, Essex County, Docket No. LT-013235-19.

Jose L. Ortiz argued the cause for appellant (Essex- Newark Legal Services, attorneys; Maria D. Castruita and Jose L. Ortiz, on the briefs).

Matthew A. Sebera argued the cause for respondent (Ehrlich, Petriello, Gudin & Plaza, attorneys; Charles R. Isaacs, on the brief).

PER CURIAM Defendant Olive Yanford appeals from an August 5, 2019 Special Civil

Part order granting a judgment of possession to plaintiff Garden Spires Urban

Renewal, LP (Garden Spires), based on defendant's alleged failure to pay rent.

Because the record shows plaintiff failed to comply with applicable federal

regulations when it increased defendant's rent, we reverse.

I.

Plaintiff is the owner of a residential housing complex in Newark, having

purchased the property in August 2018 from First King Properties, LLC (First

King), and receives funding from the United States Department of Housing and

Urban Development (HUD) under the Section 8 Program. According to

defendant, she became a tenant in the housing complex in October 2000, after

executing a lease for a subsidized apartment. At the time of the trial court

proceedings, defendant lived in the apartment with her daughter and

granddaughter.

On May 9, 2019, plaintiff filed a complaint seeking a judgment of

possession claiming defendant failed to pay $2150 in monthly rent due for

January through May 2019. Defendant moved to dismiss the complaint arguing

the court lacked jurisdiction because plaintiff failed to comply with the

applicable federal regulations when it terminated defendant's Section 8 rental

A-5382-18T1 2 subsidy and increased defendant's personal monthly rent obligations on

September 1, 2018, from $25 to $2150. On August 5, 2019, the court denied

defendant's motion to dismiss the complaint and entered a judgment of

possession. This appeal followed.

As the owner of a subsidized housing facility, plaintiff is required to

annually reexamine and determine the family income and composition of each

tenant receiving Section 8 subsidies. 24 C.F.R. § 5.657(b) (2020). Tenants, for

their part, are required to "supply any information requested by the owner or

HUD for use in a regularly scheduled reexamination or an interim reexamination

of family income and composition in accordance with HUD requirements." Id.

at § 5.659(b)(2). HUD regulations require cooperation by a tenant with the

landlord by providing information in annual recertification forms.

The policies and procedures governing the recertification process a re

contained in a handbook published by HUD. See U.S. Dep't of Hous. and Urban

Dev., HUD Handbook No. 4350.3 REV-1, Occupancy Requirements of

Subsidized Multifamily Housing Programs (2013) (HUD Handbook). "The

HUD Handbook 'is a one-source "rule book" on the occupancy policies and

procedures governing the subsidized multifamily programs' of HUD." Kuzuri

Kijiji, Inc. v. Bryan, 371 N.J. Super. 263, 265 (App. Div. 2004).

A-5382-18T1 3 All recertifications must be completed prior to the tenant's recertification

anniversary date, which is the first day of the month in which a tenant first

moved into the property. HUD Handbook at § 7–5(A), (B)(1). Such

recertifications are required to ensure "tenants pay rents commensurate with

their ability to pay." Id. at § 7–4(A).

Section 7–7A of the HUD Handbook requires owners to provide tenants

with four, separate written notices regarding a tenant's responsibility to provide

information about "changes in family income or composition necessary to

properly complete an annual recertification." The owner must provide an

"Initial Notice" each year that "serves to ensure that tenants understand that they

will need to report to the property's management office by the specified date the

following year to prepare for their next recertification." Id. at § 7–7B.1. "The

tenant must sign and date the initial notice to acknowledge receipt; the owner or

manager must sign and date the notice as a witness" and "[t]he owner must

maintain the notice with original signatures in the tenant's file and provide a

copy of the signed notice to the tenant." Id. at § 7–7B.1.b, c.

An owner must then send a tenant three reminder notices. The first must

be sent 120 days prior to the tenant's recertification anniversary date to ensure

the tenant is advised of "the cutoff date by which the tenant must contact the

A-5382-18T1 4 owner and provide the information and signatures necessary for the owner to

process the recertification." Id. at §§ 7–7B.2.a, 7–7B.2.b(5).

In the event the tenant fails to respond by failing to appear at the property's

management office, an owner is thereafter obligated to send a second reminder

notice no less than ninety days prior to the annual recertification date. Id. at §

7–7B.3.a. To the extent a tenant remains noncompliant and has not completed

the required paperwork for recertification, the owner is required to send a third

reminder notice at least sixty days prior to the recertification date. Id. at § 7–

7B.4.a.

The sixty-day notice must contain additional information including "the

amount of rent the tenant will be required to pay if the tenant fails to provide the

required recertification information by the recertification anniversary date and

state that this rent increase will be made without additional notice." Id. at § 7–

7B.4.b(2). The Handbook obligates an owner to maintain a copy of each of these

notices "in the tenant file documenting the date the notice was issued." Id. at §§

7–7B.2.c; 7–7B.3.c; 7–7B.4.c.

If the owner provides all the required notices and "[t]he tenant reports for

the recertification interview on or after the recertification anniversary date[,] "

then the "[t]enant is out of compliance." Id. at § 7–8D.3.a(2). Under these

A-5382-18T1 5 circumstances, the tenant loses his or her federal subsidy and "must begin paying

the market rent." Id. at § 7–8D.3.b. A tenant may, however, still apply for

recertification and have his or her subsidy reinstated if: "(1) [a]ssistance is

available at the property; (2) [t]he tenant submits the required information; and

(3) [t]he owner determines that the tenant qualifies for assistance." Id. at § 7–

8D.3.c.

Finally, section 7–8D.4 of the HUD Handbook also provides that "[w]hen

a tenant fails to provide the required recertification information by the

recertification anniversary date, an owner must inquire whether extenuating

circumstances prevented the tenant from responding prior to the anniversary

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GARDEN SPIRES URBAN RENEWAL, LP VS. OLIVE YANFORD (LT-013235-19, ESSEX COUNTY AND STATEWIDE), Counsel Stack Legal Research, https://law.counselstack.com/opinion/garden-spires-urban-renewal-lp-vs-olive-yanford-lt-013235-19-essex-njsuperctappdiv-2020.