Morillo v. City of New York

178 A.D.2d 7, 582 N.Y.S.2d 387, 1992 N.Y. App. Div. LEXIS 4141
CourtAppellate Division of the Supreme Court of the State of New York
DecidedMarch 26, 1992
StatusPublished
Cited by18 cases

This text of 178 A.D.2d 7 (Morillo v. City of New York) is published on Counsel Stack Legal Research, covering Appellate Division of the Supreme Court of the State of New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Morillo v. City of New York, 178 A.D.2d 7, 582 N.Y.S.2d 387, 1992 N.Y. App. Div. LEXIS 4141 (N.Y. Ct. App. 1992).

Opinions

OPINION OF THE COURT

Ross, J.

The primary issue presented by this appeal is whether certain occupants of New York City owned in rem apartment buildings have any property interest in those apartments, entitling them to special procedures before the City can move to evict them.

In the spring 1990, Mr. Richard S. Heitler (Commissioner Heitler), Assistant Commissioner, Division of Property Management, Department of Housing Preservation and Development of the City of New York (City), stated, in pertinent part, in an affidavit:

"The critical need for permanent housing for the homeless in the City is brought home by the fact that at the present time, there are 9,600 single individuals and 4,300 families housed by New York’s temporary shelters and welfare hotels. Together, the 9,600 singles and the 14,100 individuals in families represent 23,700 people in immediate need of permanent housing * * *

"The welfare hotels have received bad publicity for their crowded and often unsanitary conditions, lack of basic amenities for family living and exorbitantly high costs. The federal government has threatened to cut off Emergency Assistance payments to families that have resided in hotels for more than 30 days. For this and other reasons, the City has committed to relocating all the families from welfare hotels by the summer of 1990. Units rehabilitated in in rem housing are the bulk of the resource needed to achieve this goal”.

By 1989, as a result of in rem tax foreclosure proceedings, the City had acquired title to approximately 5,000 apartment buildings, containing approximately 50,000 apartments, and housing approximately 130,000 tenants.

[9]*9According to Commissioner Heitler "[t]hese [in rem] buildings are, for the most part, the worst of the City’s housing stock. When title finally vests in the City, after years of neglect by private owners, physical conditions are often severely deteriorated * * * Most of these buildings usually have to have essential services, like heat, hot water, and basic plumbing restored immediately. Many buildings are partially occupied, with vacancies, fire damaged apartments, and unlocked doors, making the job of providing reasonable safety for our tenants difficult”.

All in rem buildings taken by the City are managed by a unit of the City’s Department of Housing Preservation and Development (HPD), known as the Property Management Division. Those buildings, which are in the worst physical condition, and lack any tenant organization whatsover are managed directly by the City in the Central Management Program (CMP), where HPD functions as owner and managing agent, and each such building is managed by a Residential Property Manager (RPM). At this time, the City claims that CMP administers approximately 32,000 apartments in approximately 3,500 in rem buildings.

When individual vacant apartments are renovated or repaired by the HPD’s Bureau of Vacant Apartment Repair and Rental, they are used to provide housing to those who are homeless and currently in hotels or shelters. Since 1984, the City alleges that it has repaired 11,912 vacant apartments in occupied City-owned in rem buildings and provided them to homeless families.

Commissioner Heitler contends that:

"In the continuing effort to assert control over its buildings and to safeguard our tenants, it is drug dealers who are our greatest enemy * * *

"According to Police Department records, 2,282 arrests for possession and sale of narcotics were made in City-owned buildings in 1989. We believe that this statistic underreports the actual number of drug arrests in our buildings, to say nothing of the activity that goes on without arrests * * *

"In 1988 HPD created the Narcotics Control Unit headed by a former police detective whose job is to investigate and gain information as to the use of drugs and drug selling in City-owned buildings, to coordinate arrests of drug dealers with the Police Department and to coordinate evictions of drug dealers [10]*10from City-owned apartments with HPD’s Tenant Legal Affairs Unit (TLAU) * * *

"This effort has resulted in the evictions of the former occupants of more than 1600 of our apartments. By and large the bulk of the drug dealers that we have evicted have been illegal occupants of our buildings. Of the 1600 drug-related evictions referred to above, approximately two-thirds have been either squatters or licensees * * *

"[T]he drug problem remains one of our worst and most dangerous problems in the management of our housing stock”.

Due to the fact that HPD was losing over 60 vacant in rem apartments a month to illegal occupants, such as squatters, on March 15, 1988, it instituted the Vacant Apartment Security Program (VASP), requiring RPMs of in rem buildings to regularly visit such apartments, protect them with locks, and, if squatters were found, to immediately report their presence to HPD’s Tenant Legal Affairs Unit to commence eviction proceedings.

After the initiation of VASP, HPD decided that it would no longer routinely seek the eviction of all squatters, since that "practice was inconsistent and unpredictable and resulted in the eviction of people and families whose eviction was not good public policy”, and therefore, on or about November 1, 1988, the City promulgated the Unauthorized Occupant Policy (UOP), which had been developed, "in order to gather information to evaluate identified unauthorized occupants, and to allow HPD in its discretion to authorize tenancies where appropriate”.

Our examination of the provisions of the UOP indicates that it contains a preamble, which states, in pertinent part that, "[a]ll unauthorized occupants in residence as of April 1, 1988 are to be evaluated on a case by case basis to determine whether they would be acceptable as legal tenants. Occupants will be evaluated based on their household composition, residence history, involvement in unacceptable activities and willingness to pay rent and arrears”.

Under the UOP each RPM is required to make a good-faith effort to interview all unauthorized occupants in his or her building and then complete a questionnaire.

Further, the UOP establishes three categories of households. First, "priority households”, which include senior citizens, mentally or physically handicapped individuals, pregnant women, or children under the age of 18. Second, "claim of [11]*11right households”, which include a member whose residency relates back to a legal tenant. Third, "special circumstances households”, encompassing a broad group of persons, which equity favors allowing them to become legal tenants.

If a household falls within one of the three designated types of households, is "not involved in unacceptable activities and [is] willing to pay rent and arrears [it] will be referred to the Bureau of Vacant Apartment Repair and Rental (BVARR) to be set up as legal tenants”. The UOP states that "[e]xamples of unacceptable activity include, but are not limited to, drug trafficking, prostitution, organized gambling, attacking or threatening other residents of the building, damaging or defacing any portion of the building, generating excessive traffic of people and/or materials in and out of the building, and generating loud noise which is disturbing to other residents”.

The cutoff date for UOP evaluation is April 1, 1988. Accordingly, UOP is not applicable to illegal occupants who began living in their apartments after April 1, 1988.

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Cite This Page — Counsel Stack

Bluebook (online)
178 A.D.2d 7, 582 N.Y.S.2d 387, 1992 N.Y. App. Div. LEXIS 4141, Counsel Stack Legal Research, https://law.counselstack.com/opinion/morillo-v-city-of-new-york-nyappdiv-1992.