S&P Assoc. of N.Y. LLC v. Dewald

2024 NY Slip Op 32187(U)
CourtNew York Supreme Court, New York County
DecidedJune 27, 2024
StatusUnpublished

This text of 2024 NY Slip Op 32187(U) (S&P Assoc. of N.Y. LLC v. Dewald) 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
S&P Assoc. of N.Y. LLC v. Dewald, 2024 NY Slip Op 32187(U) (N.Y. Super. Ct. 2024).

Opinion

S&P Assoc. of N.Y. LLC v Dewald 2024 NY Slip Op 32187(U) June 27, 2024 Supreme Court, New York County Docket Number: Index No. 159779/2023 Judge: Louis L. Nock 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. 159779/2023 NYSCEF DOC. NO. 131 RECEIVED NYSCEF: 06/27/2024

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. LOUIS L. NOCK PART 38M Justice ---------------------------------------------------------------------------------X INDEX NO. 159779/2023 S&P ASSOCIATES OF NEW YORK LLC, 11/27/2023, Plaintiff, MOTION DATE 11/27/2023

-v- MOTION SEQ. NO. 004 005

JEROME DEWALD, KRISTINA DEWALD, and AIRBNB, INC., DECISION + ORDER ON MOTION Defendants. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document numbers (Motion 004) 94, 95, 103, 109, 115, and 122 were read on this motion by defendant Airbnb, Inc., TO DISMISS THE COMPLAINT .

The following e-filed documents, listed by NYSCEF document numbers (Motion 005) 96, 97, 104, 105, 110, 111, 112, 113, 114, 117, 119, 120, 121, 124, 125, 126, and 129 were read on this motion by defendant Jerome Dewald TO DISMISS THE COMPLAINT .

LOUIS L. NOCK, J.

Upon the foregoing documents, and after oral argument convened on the record, it is

ordered that the motions to dismiss the verified complaint (the “Complaint”), filed by defendant

Airbnb, Inc. (Mot Seq. No. 004), and defendant pro se Jerome Dewald (Mot Seq. No. 005),

respectively, are consolidated herein for disposition and determined as follows.1

1 The Complaint asserts the same causes of action against both Dewald defendants – Jerome Dewald and Kristina Dewald, who are husband and wife, and tenants of the subject apartment. Thus, the analysis herein applies to both of them notwithstanding the fact that Mr. Dewald – a pro se party – is the sole signatory of the notice of motion (NYSCEF Doc. No. 96). The court views both defendants, who are identical in interest, as the movants. To the extent that the within discussion and disposition refer to Mr. Dewald only, the intent is to include Ms. Dewald. 159779/2023 S&P ASSOCIATES OF NEW YORK LLC vs. DEWALD, JEROME ET AL Page 1 of 13 Motion No. 004 005

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Background2

Plaintiff brings this action for violations of a lease and New York City’s Local Law 18

for the year 2022 (“Local Law 18”) (Administrative Code of the City of New York §§ 26-3101,

et seq. and §§ 26-3201, et seq.). Plaintiff S&P Associates of New York LLC, the owner and

landlord of a building located at 30 West 63rd Street in Manhattan (the “Building”), alleges that

defendants, Jerome Dewald and Kristina Dewald (“Tenants”), are engaging in short-term rentals

of their apartment through online platforms, including co-defendant Airbnb, Inc. (“Airbnb”).

Plaintiff and Tenants entered into a lease, dated June 5, 2017, for an apartment within the

Building (the “Premises”), which expired, by its terms, on August 31, 2020 (see Lease, exhibit

A, NYSCEF Doc. No. 3). Tenants continued to occupy the Premises on a month-to-month basis

subject to the terms of the expired lease.

The terms of the lease restrict the use of the Premises to the private residence of Tenants

and their immediate family (id. at 1 [“Use of Apartment”]). A rider to the lease further prohibits

short-term occupancy by individuals other than Tenants and their immediate family as well as

advertising of the Premises by Tenants for short-term rental on Airbnb and similar platforms (id.

at 11 [“Rider to the Lease”]). A violation of said provision constitutes a material breach of the

lease (see, id.). As set forth in the affidavits of plaintiff’s managing agent, Tenants allegedly

advertised and rented out the Premises via Airbnb from March 2023 to November 2023 (Jeffrey

Pirkl affidavit, NYSCEF Doc. No. 6 at 80). In addition to such alleged breach of lease and

violation of Local Law, plaintiff alleges that such transient activity threatens the safety and well-

being of residents of the Building.

2 Allegations of the Complaint (NYSCEF Doc. No. 2) are taken as true for the purposes of these motions to dismiss. 159779/2023 S&P ASSOCIATES OF NEW YORK LLC vs. DEWALD, JEROME ET AL Page 2 of 13 Motion No. 004 005

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In October 2023, plaintiff commenced this action seeking a permanent injunction against

Tenants (first cause of action) barring them from engaging in short-term rentals of the Premises

through Airbnb and other platforms, as well as against Airbnb (second cause of action) barring it

from permitting Tenants to advertise or rent out the Premises on its platform and from releasing

funds to Tenants gained from such rentals. Plaintiff also seeks a declaratory judgment (third

cause of action) that the lease and Local Law 18 prohibit Tenants from procuring short-term

rentals of the Premises and that Local Law 18 proscribes Airbnb from allowing the use of its

platform for listing short-term rentals of the Premises. Furthermore, plaintiff brings claims for

breach of contract (fourth cause of action) and unjust enrichment (fifth cause of action) against

Tenants, as well as for civil penalties pursuant to Local Law 18 against Tenants (sixth cause of

action). Defendants Airbnb and Jerome Dewald move to dismiss the complaint for failure to

allege a cause of action. The motions are opposed.

Standard of Review

“On a motion to dismiss pursuant to CPLR 3211, the pleading is to be afforded a liberal

construction” (Leon v Martinez, 84 NY2d 83, 87 [1994]). “[The court] accept[s] the facts as

alleged in the complaint as true, accord[ing] plaintiffs the benefit of every possible favorable

inference, and determin[ing] only whether the facts as alleged fit within any cognizable legal

theory” (id. at 87-88). Ambiguous allegations must be resolved in plaintiff’s favor (JF Capital

Advisors, LLC v Lightstone Group, LLC, 25 NY3d 759, 764 [2015]). “The motion must be

denied if from the pleadings’ four corners factual allegations are discerned which taken together

manifest any cause of action cognizable at law” (511 W. 232nd Owners Corp. v Jennifer Realty

Co., 98 NY2d 144, 152 [2002] [citations omitted]). “[W]here . . . the allegations consist of bare

legal conclusions, as well as factual claims either inherently incredible or flatly contradicted by

159779/2023 S&P ASSOCIATES OF NEW YORK LLC vs. DEWALD, JEROME ET AL Page 3 of 13 Motion No. 004 005

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documentary evidence, they are not entitled to such consideration” (Ullmann v Norma Kamali,

Inc., 207 AD2d 691, 692 [1st Dept 1994]).

Discussion

A. Local Law 18 (Sixth Cause of Action for Civil Penalties)

Enacted in January 2022 and effective September 2023, Local Law 18, also known as the

Short-Term Rental Registration Law, requires the registration of short-term rentals for fewer

than 30 days with the Mayor’s Office of Special Enforcement (the “OSE”) (Administrative Code

§§ 26-3101, et seq. and §§ 26-3201, et seq.). A host or person seeking to offer short-term rentals

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Bluebook (online)
2024 NY Slip Op 32187(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/sp-assoc-of-ny-llc-v-dewald-nysupctnewyork-2024.