Tenant Rent Regulation Research Initiative v. New York State Div. of Hous. & Community Renewal

2025 NY Slip Op 33017(U)
CourtNew York Supreme Court, Kings County
DecidedJuly 21, 2025
DocketIndex No. 531578/2024
StatusUnpublished

This text of 2025 NY Slip Op 33017(U) (Tenant Rent Regulation Research Initiative v. New York State Div. of Hous. & Community Renewal) is published on Counsel Stack Legal Research, covering New York Supreme Court, Kings County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tenant Rent Regulation Research Initiative v. New York State Div. of Hous. & Community Renewal, 2025 NY Slip Op 33017(U) (N.Y. Super. Ct. 2025).

Opinion

Tenant Rent Regulation Research Initiative v New York State Div. of Hous. & Community Renewal 2025 NY Slip Op 33017(U) July 21, 2025 Supreme Court, Kings County Docket Number: Index No. 531578/2024 Judge: Gina Abadi 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. FILED: KINGS COUNTY CLERK 08/04/2025 11:17 AM INDEX NO. 531578/2024 NYSCEF DOC. NO. 68 RECEIVED NYSCEF: 08/04/2025

At an IAS Term, Part 18 of the Supreme Court of the State of New York, held in and for the County of Kings, at the Courthouse, at Civic Center, Brooklyn, New York, on the 21st day of July, 2025. P R E S E N T:

HON. GINA ABADI, Justice. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X TENANT RENT REGULATION RESEARCH INITIATIVE and HALLEY POTTER,

Petitioners, Index No. 531578/2024

- against - Motion Seq. 1

NEW YORK STATE DIVISION OF HOUSING AND COMMUNITY RENEWAL,

Respondent. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X The following e-filed papers read herein: NYSCEF Doc Nos.

Notice of Motion/Order to Show Cause/ Petition/Cross Motion and Affidavits (Affirmations) Annexed 1-34 Opposing Affidavits (Affirmations) 49-56 Reply Affidavits (Affirmations) 58-67

Upon the foregoing papers in this Article 78 proceeding, petitioners Tenant Rent

Regulation Research Initiative (T3RI) and Halley Potter (Potter) (collectively, petitioners)

seek a judgment, pursuant to CPLR Article 78 (in motion sequence [mot. seq.] one): (1)

directing respondent New York State Division of Housing and Community Renewal

(DHCR) to comply with its duty under New York’s Freedom of Information Law (FOIL)

to provide petitioners with access to the records petitioners requested in their May 22, 2024

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and August 8, 2024 FOIL requests, and (2) awarding petitioners reasonable attorneys’ fees

and litigation costs, pursuant to Public Officers Law § 89 (4) (NYSCEF Doc No. 2).

Background

On November 21, 2024, petitioners commenced this Article 78 proceeding by filing

a petition alleging that “[t]his proceeding arises out of Respondent’s failure to disclose

certain information requested by Petitioner[s] relating to cases brought before DHCR’s

Office of Rent Administration (‘ORA’)” in violation of FOIL (Petition at ¶ 2). Specifically,

on May 22, 2024, T3RI requested two tables from DHCR’s computerized recordkeeping

system, the Historical Updates and Tracking System database (HUTS), including

“anonymized information detailing the cases ORA has processed, their types, processing

dates and outcomes, and major events” (NYSCEF Doc No. 34 at 5). Regarding DHCR’s

denial of T3RI’s first Foil request, the petition alleges that:

“[o]n June 27, 2024, DHCR’s Records Access Officer (‘RAO’) denied the request in full, on the purported grounds, as relevant here, that ‘significant portions of the data relate to registration information, which is exempt from disclosure under [FOIL] based on Rent Stabilization Law § 26-517(b). The RAO further purported to determine that ‘ORA does not possess an existing report that includes the database tables you cited. The Public Officers Law does not require us to compile this information or create a new report to respond to a FOIL request’” (petition at ¶ 10).

On July 23, 2024, T3RI submitted an administrative appeal to DHCR challenging

the denial of its FOIL request (id. at ¶ 11). On August 8, 2024, the DHCR denied T3RI’s

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appeal on the grounds that Tenant Protection Regulations1 render registration information

exempt under FOIL (id. at ¶ 13). The DHCR also relied on § 8586.6 of the Emergency

Housing Rent Control Act, which “commanded that the agency ‘not publish or disclose

any information obtained under this act that the commission deems confidential or with

reference to which a request for confidential treatment is made by the person furnishing

such information’” (id.). DHCR also asserted that ORA would have to create a report

containing the data requested by T3RI because it does not have such a report, and FOIL

does not require an entity to prepare or compile a new report in response to a FOIL request.

On August 8, 2024, T3RI submitted a second FOIL request “narrowing its request

to only a small subset of the information in the data tables it had initially requested” “to

avoid any information DHCR had found to be exempt in its denial of the first request . . .”

(id. at ¶12). The second FOIL request also did not seek registration information and only

requested records concerning rent stabilized housing accommodations (id.). The second

FOIL request sought “fields containing basic anonymized metadata about the cases: their

docket numbers, the housing accommodations to which they applied, their outcomes, and

DHCR’s log of major events in their processing” (NYSCEF Doc No. 34 at 7).

On September 10, 2024, DHCR denied T3RI’s second FOIL request on the ground

that the request was ‘duplicative’ of T3RI’s first FOIL request (petition at ¶ 14). On

September 13, 2024, T3RI appealed from the DHCR’s denial of its second FOIL request

(id. at ¶ 15). On October 7, 2024, DHCR denied T3RI’s second administrative appeal on

1 DHCR referenced § 2528.5 of the Rent Stabilization Code and § 2509.4 of the Tenant Protection Regulations, both of which govern rent stabilized apartments (NYSCEF Doc No. 7 at 1). 3

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the same grounds as DHCR’s denial of the first appeal and because the second FOIL

request was “duplicative” of the first FOIL request (id. at ¶ 16). To date, DHCR has not

released any documents in response to T3RI’s two FOIL requests (id. at ¶ 17).

The petition alleges that “DHCR has wrongly withheld documents under claimed

statutory exemptions that do not properly apply or has purported to withhold documents

for reasons that are not statutory exemptions” and “failed to provide a specific and

particularized justification for withholding each document or portion thereof that it is

refusing to disclose” (id. at ¶¶ 19 and 25). The petition also alleges that DHCR “has refused

to perform a duty enjoined upon it by FOIL, erred as a matter of law, and otherwise acted

arbitrarily and capriciously” and “[its] failure has caused, and continues to cause,

immediate and irreparable harm to the rights guaranteed to T3RI and to the public at large

under FOIL” (id. at ¶¶ 26-27).

Petitioner submits a memorandum of law explaining that T3RI requested data

reflecting how ORA processes tenant complaints so it can “update a 2013 audit by the New

York State Comptroller identifying serious flaws and multi-year delays that can deter

tenants from even attempting to assert their rights” (NYSCEF Doc No. 34 at 1). Petitioners

assert that “[i]n violation of FOIL, DHCR refused to disclose data that would show how

the backlog and wait times have changed over time, and whether case processing times

differ by geography, or in buildings where the agency has already found rent manipulation”

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2025 NY Slip Op 33017(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/tenant-rent-regulation-research-initiative-v-new-york-state-div-of-hous-nysupctkings-2025.