Matter of Cheng v. State of New York Div. of Hous. & Community Renewal Off. of Rent Admin.

2024 NY Slip Op 31072(U)
CourtNew York Supreme Court, New York County
DecidedMarch 29, 2024
StatusUnpublished

This text of 2024 NY Slip Op 31072(U) (Matter of Cheng v. State of New York Div. of Hous. & Community Renewal Off. of Rent Admin.) 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
Matter of Cheng v. State of New York Div. of Hous. & Community Renewal Off. of Rent Admin., 2024 NY Slip Op 31072(U) (N.Y. Super. Ct. 2024).

Opinion

Matter of Cheng v State of New York Div. of Hous. & Community Renewal Off. of Rent Admin. 2024 NY Slip Op 31072(U) March 29, 2024 Supreme Court, New York County Docket Number: Index No. 155861/2023 Judge: John J. Kelley 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. 155861/2023 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 03/30/2024

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. JOHN J. KELLEY PART 56M Justice ---------------------------------------------------------------------------------X INDEX NO. 155861/2023 In the Matter of 8/31/2023 STEPHEN CHENG, MOTION DATE 11/08/2023

Petitioner, MOTION SEQ. NO. 001, 003

-v- STATE OF NEW YORK DIVISION OF HOUSING AND DECISION + ORDER ON COMMUNITY RENEWAL OFFICE OF RENT ADMINISTRATION, MOTION

Respondent. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 001) 16, 17, 18, 19, 20, 22 were read on this motion to/for CONSOLIDATE/JOIN FOR TRIAL .

The following e-filed documents, listed by NYSCEF document number (Motion 003) 30, 31, 32, 33, 34, 35, 36, 37, 38, 39 were read on this motion to/for INTERVENTION/DISMISSAL .

In this proceeding pursuant to CPLR article 78, the tenant petitioner seeks judicial review

of a May 11, 2023 New York State Division of Housing and Community Renewal (NYS DHCR)

determination denying, in part, his Petition for Administrative Review (PAR) of a Rent

Administrator’s May 28, 2021 decision that was adverse to him. The May 11, 2023

determination was made pursuant to a June 14, 2022 order (Love, J.), remitting the matter to

the NYS DHCR for reconsideration (see Matter of Cheng v State of N.Y. Div. of Hous. &

Community Renewal, Index No. 150439/2022 [Sup Ct, N.Y. County, Jun. 14, 2022]).

The petitioner now moves pursuant to CPLR 602(a) to consolidate this proceeding with a

related proceeding entitled Matter of 30 West 88 Realty, LLC v New York State Div. of Hous. &

Community Renewal, pending before this court under Index No. 156848/2023, in which the

155861/2023 IN THE MATTER OF THE APPLICATION OF STEPHEN CHENG vs. STATE OF NEW Page 1 of 5 YORK DIVISION OF HOUSING AND COMMUNITY RENEWAL OFFICE OF RENT ADMINISTRATION Motion No. 001

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petitioner’s landlords, 30 West 88 Realty, LLC, and SM 30W88, LLC (the landlords), seek

judicial review of the same NYS DHCR determination (MOT SEQ 001). The NYS DHCR does

not oppose the motion. The landlords move pursuant to CPLR 1012(a) for leave to intervene in

the instant proceeding, and thereupon pursuant to CPLR 3211(a)(10) to dismiss the petition

herein for failure to join them as necessary parties (MOT SEQ 003). The petitioner and NYS

DHCR oppose that branch of the motion seeking dismissal of the petition. The petitioner’s

motion is granted. The landlords’ motion is granted to the extent that they are granted leave to

intervene in the proceeding commenced by the petitioner, and their motion is otherwise denied.

“Consolidation is generally favored in the interest of judicial economy and ease of

decision-making where cases present common questions of law and fact, ‘unless the party

opposing the motion demonstrates that a consolidation will prejudice a substantial right’” (Raboy

v McCrory Corp., 210 AD2d 145 [1st Dept 1994], quoting Amtorg Trading Corp. v Broadway &

56th St. Assoc., 191 AD2d 212, 213 [1st Dept 1993]). The issue raised in both the related

proceeding and this proceeding are whether the May 11, 2023 determination was arbitrary and

capricious or affected by an error of law. There no indication that consolidation of the two

proceedings will prejudice a substantial right of any party (see Amcan Holdings, Inc. v Torys

LLP, 32 AD3d 337 [1st Dept 2006]).

The landlords’ intervention in the proceeding commenced by the petitioner is warranted

here, as they clearly have a direct and substantial interest in the outcome of the litigation (see

CPLR 1012[a][2]; Burlingame v State of New York, 42 AD3d 923, 924 [4th Dept 2007]).

Dismissal, however, is not warranted. Where a necessary party has not been joined, the court

may not dismiss the matter for failure to join a necessary party, even where the applicable

limitations period has lapsed. “When a person who should be joined . . . has not been made a

party and is subject to the jurisdiction of the court, the court shall order him summoned” (CPLR

1001[b]). Hence, the court must direct the unnamed necessary party to be joined, subject to its

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assertion of all applicable defenses and affirmative defenses, including the statute of limitations

(see CPLR 1001[a]; Windy Ridge Farm v Assessor of Town of Shandaken, 11 NY3d 725, 727

[2008]; Matter of Red Hook/Gowanus Chamber of Commerce v New York City Bd. of Stds. &

Appeals, 5 NY3d 452 [2005]; Rosioreanu v New York City Off. of Collective Bargaining, 78

AD3d 401, 401 [1st Dept 2010]; Matter of 37 W. Realty Co. v New York City Loft Bd., 72 AD3d

406, 406 [1st Dept 2010]; Matter of Lazzari v Town of Eastchester, 62 AD3d 1002 [2d Dept

2009], affd 20 NY3d 214 [2012]; Friedland v Hickox, 60 AD3d 426, 426 [1st Dept 2009]). Thus,

even had the landlords not intervened, the court was required to order their joinder in any event.

The court notes that the landlords, whether appearing via intervention or joinder, could raise the

issue of whether the proceeding was time-barred as to it, and that dismissal of the entirety of the

petition should eventuate. The landlords, however, named and joined the petitioner as a

respondent in the related proceeding, which is now consolidated into the initial proceeding, and

both proceedings will obligate the court to review the NYS DHCR’s determination (see CPLR

7803[3]). These facts warrant the conclusion that, even if the landlords were dismissed from the

petitioner’s proceeding despite being necessary parties, that matter would have been able to

proceed even in their absence (see CPLR 1001[b][5] [court must consider whether an effective

judgment may be rendered in the absence of the party not joined]; Matter of 27th St. Block

Assn. v Dormitory Auth. of State of N.Y., 302 AD2d 155, 163 [1st Dept 2002]).

Accordingly, it is,

ORDERED that the motion of 30 West 88 Realty, LLC, and SM 30W88, LLC (SEQ 003),

is granted to the extent that they are permitted to intervene as respondents in the proceeding

entitled Matter of Cheng v State of New York Division of Housing and Community Renewal,

commenced in the Supreme Court, New York County, under Index No. 155861/2023, and their

motion is otherwise denied; and it is further,

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Related

Windy Ridge Farm v. Assessor of the Town of Shandaken
894 N.E.2d 1183 (New York Court of Appeals, 2008)
Red Hook/Gowanus Chamber of Commerce v. New York City Board of Standards
839 N.E.2d 878 (New York Court of Appeals, 2005)
Lazzari v. Town of Eastchester
981 N.E.2d 777 (New York Court of Appeals, 2012)
Amcan Holdings, Inc. v. Torys LLP
32 A.D.3d 337 (Appellate Division of the Supreme Court of New York, 2006)
Burlingame v. State
42 A.D.3d 923 (Appellate Division of the Supreme Court of New York, 2007)
Friedland v. Hickox
60 A.D.3d 426 (Appellate Division of the Supreme Court of New York, 2009)
Lazzari v. Town of Eastchester
62 A.D.3d 1002 (Appellate Division of the Supreme Court of New York, 2009)
37 West Realty Co. v. New York City Loft Board
72 A.D.3d 406 (Appellate Division of the Supreme Court of New York, 2010)
Rosioreanu v. New York City Office of Collective Bargaining
78 A.D.3d 401 (Appellate Division of the Supreme Court of New York, 2010)
Amtorg Trading Corp. v. Broadway & 56th Street Associates
191 A.D.2d 212 (Appellate Division of the Supreme Court of New York, 1993)
27th Street Block Ass'n v. Dormitory Authority
302 A.D.2d 155 (Appellate Division of the Supreme Court of New York, 2002)

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Bluebook (online)
2024 NY Slip Op 31072(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/matter-of-cheng-v-state-of-new-york-div-of-hous-community-renewal-off-nysupctnewyork-2024.