Inglis v. Four Thirty Realty LLC

2024 NY Slip Op 31676(U)
CourtNew York Supreme Court, New York County
DecidedMay 13, 2024
StatusUnpublished

This text of 2024 NY Slip Op 31676(U) (Inglis v. Four Thirty Realty LLC) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Inglis v. Four Thirty Realty LLC, 2024 NY Slip Op 31676(U) (N.Y. Super. Ct. 2024).

Opinion

Inglis v Four Thirty Realty LLC 2024 NY Slip Op 31676(U) May 13, 2024 Supreme Court, New York County Docket Number: Index No. 160419/2019 Judge: Paul A. Goetz Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 160419/2019 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 05/13/2024

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. PAUL A. GOETZ PART 47 Justice ---------------------------------------------------------------------------------X INDEX NO. 160419/2019 STEVEN R INGLIS, JULIA ODDY INGLIS MOTION DATE 10/02/2023 Plaintiff, MOTION SEQ. NO. 001 -v- FOUR THIRTY REALTY LLC, DECISION + ORDER ON MOTION Defendant. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 001) 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 60, 61, 62, 63, 64, 65, 66, 67, 68, 69, 70, 71, 72, 73, 74, 75, 76, 77, 78, 79, 90, 91, 92, 96, 109, 112, 113, 114, 115, 117, 118, 119, 120, 121 were read on this motion to/for PARTIAL SUMMARY JUDGMENT .

Upon the foregoing documents, it is

In this rent overcharge action involving a building receiving J-51 tax benefits, plaintiffs

move pursuant to CPLR § 3124 to compel defendant to provide documents and answers to

interrogatories, the purpose of which are to determine whether defendant participated in a

fraudulent scheme to deregulate plaintiffs’ apartment. Plaintiff also moves pursuant to CPLR §

2307 seeking judicial approval of two subpoenas which seek records from the HPD and the

DHCR. Defendants cross move pursuant to CPLR § 3103 seeking a protective order striking

plaintiffs’ discovery demands and pursuant to CPLR § 2304 to quash the subpoenas to HPD and

the DHCR.

DISCUSSION

Applicable Standard

“A provision added as part of the Rent Regulation Reform Act of 1997 (1997 RRRA)

expressly preclude[d] examination of the rental history of the housing accommodation prior to

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the four-year period preceding commencement of the overcharge action” (Regina Metro. Co.,

LLC v New York State Div. of Hous. and Community Renewal, 35 NY3d 332, 353 [2020]

[internal quotation marks removed]). However, there is a “a limited common-law exception to

the otherwise-categorical evidentiary bar, permitting tenants to use such evidence only to prove

that the owner engaged in a fraudulent scheme to deregulate the apartment” (id. at 354). The

exception requires a tenant to have a “colorable claim of fraud by identifying… evidence, of a

landlord's fraudulent deregulation scheme to remove an apartment from the protections of rent

stabilization” (id. at 355 [internal quotation marks removed]).

During discovery, “the question is not whether fraud has been demonstrated, but rather

whether fraud could be shown” (Ioannou v 1 BK St. Corp., 203 AD3d 627 [1st Dept 2022]).

“Fraud consists of ‘evidence [of] a representation of material fact, falsity, scienter, reliance and

injury’” (Regina, 35 NY3d 356 n.7 [quoting [Vermeer Owners v Guterman, 78 NY2d 1114, 1116

[1991]]]). Since the Regina decision courts have held that in order for the fraud exception to the

lookback rule to apply the “plaintiffs [are] required to prove, prima facie, the [common law]

elements of fraud” (Aras v B-U Realty Corp., 221 AD3d 5, 12 [1st Dept 2023]).

However, recently the legislature passed 2023 New York Senate Bill No 2980 and 2024

New York Senate Bill No 8011, which changes the definition of “fraud” within the context of the

fraud exception to the four-year lookback rule. These bills require an examination of the totality

of the circumstances when determining if a fraudulent scheme to deregulate an apartment

transpired, rather than requiring a showing of each of the five elements of common law fraud.

While defendants argue that the new statute is unconstitutional as it retroactively punishes past

conduct and imposes new liability for completed transactions, the law’s constitutionality on this

discovery motion need not be addressed because as will be shown below, plaintiffs have

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demonstrated that they have a colorable claim of fraud under the more stringent common-law

fraud standard.

Representation of Material Fact

Plaintiff Steven R. Inglis submits an affidavit in which he states that the initial lease they

received and signed stated “'THIS APARTMENT IS NOT SUBJECT TO RENT

STABILIZATION" (NYSCEF Doc No 90 ¶ 7). Plaintiffs allege that throughout their tenancy

they were never notified that the apartment is rent stabilize, they never received a lease on

DHCR’s official form, rent registration form nor, a mandatory rights rider that is required to be

included with every lease for a regulated apartment, and that their rent increases have never been

described as limited by law (id. at ¶ 8).

Falsity

It is undisputed that plaintiff’s apartment should have been rent stabilized due to

defendant receiving J-51 tax benefits. On June 15, 2012, and affirmed on appeal on April 14,

2015, the building was found to be rent stabilized because it was receiving J-51 tax benefits in a

case brought by another tenant in defendant’s building (Meyers v Four Thirty Realty, 127 AD3d

501 [1st Dept 2015]) (NYSCEF Doc. No. 29).

Scienter

Plaintiffs argues that defendant must have been aware of these misrepresentations and

lack of disclosure because even after the decision in Meyers v. Four Thirty Realty LLC

(NYSCEF Doc. No. 29) defendant never satisfied its legal duty to correct the misrepresentation

that the apartment was unregulated. Defendant never provided plaintiffs with a rent stabilized

lease and never recalculated plaintiffs’ rent despite knowing that the building was regulated

because of its receipt of J-51 benefits. Defendant argues that “scienter” cannot be shown because

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there is no proof that defendant “knowingly engaged” in a fraudulent scheme, and that it

deregulated the units because it relied on DHCR policy, which was later deemed an invalid

interpretation of the statutory scheme (Roberts v Tishman Speyer Properties, L.P., 13 NY3d 270

[2009]).

An “[o]wner [does] not engage in fraud when it improperly removed the apartment from

rent regulation because it was relying on DHCR's own contemporaneous interpretation of the

relevant laws and regulations” (Park v New York State Div. of Hous. and Community Renewal,

150 AD3d 105, 106 [1st Dept 2017]). However, in Ioannou, the First Department denied a

motion to quash a subpoena on the DHCR because “at this stage of the litigation, the question is

not whether fraud has been demonstrated, but rather whether fraud could be shown” and “the

rent roll registration records sought in the subpoena are relevant to determine whether defendant

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Related

Meyers v. Four Thirty Realty
127 A.D.3d 501 (Appellate Division of the Supreme Court of New York, 2015)
Matter of Park v. New York State Div. of Hous. & Community Renewal
2017 NY Slip Op 2745 (Appellate Division of the Supreme Court of New York, 2017)
Montera v. KMR Amsterdam LLC
2021 NY Slip Op 00805 (Appellate Division of the Supreme Court of New York, 2021)
Roberts v. Tishman Speyer Properties, L.P.
918 N.E.2d 900 (New York Court of Appeals, 2009)
Vermeer Owners, Inc. v. Guterman
585 N.E.2d 377 (New York Court of Appeals, 1991)
Ioannou v. 1 BK St. Corp.
163 N.Y.S.3d 398 (Appellate Division of the Supreme Court of New York, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
2024 NY Slip Op 31676(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/inglis-v-four-thirty-realty-llc-nysupctnewyork-2024.