USC 462 W. 141 LLC v. Richards

2025 NY Slip Op 34948(U)
CourtCivil Court Of The City Of New York, New York County
DecidedJanuary 9, 2026
DocketIndex No. L&T 312360/25
StatusUnpublished
AuthorClinton J. Guthrie

This text of 2025 NY Slip Op 34948(U) (USC 462 W. 141 LLC v. Richards) is published on Counsel Stack Legal Research, covering Civil Court Of The City Of New York, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
USC 462 W. 141 LLC v. Richards, 2025 NY Slip Op 34948(U) (N.Y. Super. Ct. 2026).

Opinion

USC 462 W. 141 LLC v Richards 2025 NY Slip Op 34948(U) January 9, 2026 Civil Court of the City of New York, New York County Docket Number: Index No. L&T 312360/25 Judge: Clinton J. Guthrie 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. LT-312360-25/NY FILED: NEW YORK CIVIL COURT - L&T 01/09/2026 05:18 PM NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 01/09/2026

CIVIL COURT OF THE CITY OF NEW YORK COUNTY OF NEW YORK: HOUSING PART D ---------------------------------------------------------------X USC 462 WEST 141 LLC a/k/a USC 462 W 141 LLC, Index No. L&T 312360/25 Petitioner,

-against- DECISION/ORDER

CHARMAINE RICHARDS,

Respondent. ----------------------------------------------------------------X Present:

Hon. CLINTON J. GUTHRIE Judge, Housing Court

Recitation, as required by CPLR § 2219(a), of the papers considered in the review of respondent’s motion for summary judgment pursuant to CPLR § 3212 and MDL § 302(1)(b):

Papers Numbered

Notice of Motion & All Documents Annexed…………....…..... 1 (NYSCEF #14-17) Affirmation in Opposition & Exhibit Annexed…….....……….. 2 (NYSCEF #20-21) Affirmation in Further Support (Reply)………………..………. 3 (NYSCEF #22)

Upon the foregoing cited papers, the decision and order on respondent’s motion is as follows.

PROCEDURAL HISTORY

This summary nonpayment proceeding was filed in July 2025. Respondent filed a pro se

answer on August 14, 2025. Respondent later retained counsel and interposed an amended

answer on October 10, 2025 on consent. Respondent now moves for summary judgment upon

her defense grounded in Multiple Dwelling Law (MDL) § 302. Following the submission of

opposition and reply papers, this court heard argument on the motion on January 9, 2026.

1 of 5 [* 1] INDEX NO. LT-312360-25/NY FILED: NEW YORK CIVIL COURT - L&T 01/09/2026 05:18 PM NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 01/09/2026

DISCUSSION/CONCLUSION

On a motion for summary judgment, “the proponent . . . must make a prima facie

showing of entitlement to judgment as a matter of law, tendering sufficient evidence to

demonstrate the absence of any material issues of fact[.] . . . Once this showing has been made,

however, the burden shifts to the party opposing the motion for summary judgment to produce

evidentiary proof in admissible form sufficient to establish the existence of material issues of fact

which require a trial of the action.” (Alvarez v. Prospect Hosp., 68 N.Y.2d 320, 324 [1986]

[internal citations omitted]). In support of her motion, respondent annexes certain HPD (NYC

Department of Housing Preservation and Development) and OATH/ECB (NYC Office of

Administrative Trials and Hearings/Environmental Control Board) violations issued for the

subject building. Respondent argues that the violations constitute evidence that the subject

building is occupied contrary to its certificate of occupancy and, as a result, petitioner is

precluded from maintaining this proceeding for nonpayment of rent pursuant to MDL §

302(1)(b). Petitioner opposes the motion in all respects, primarily arguing that the violations

annexed by respondent are not dispositive evidence of occupancy that would preclude collection

of rent. Petitioner also argues that it would be inequitable for respondent to raise the MDL § 302

defense in this proceeding, after failing to raise it in prior proceedings.

Under MDL § 302(1)(b), no rent shall be recovered and no action or proceeding for the

nonpayment of rent shall be maintained if any dwelling or structure is occupied in whole or in

part for human habitation in violation of MDL § 301, which governs certificates of occupancy

(see Chazon, LLC v Maugenest, 19 NY3d 410, 413 [2012]). The statute will apply if the

premises lacks a certificate of occupancy (see 49 Bleecker, Inc. v Gatien, 157 AD3d 619 [1st

2 of 5 [* 2] INDEX NO. LT-312360-25/NY FILED: NEW YORK CIVIL COURT - L&T 01/09/2026 05:18 PM NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 01/09/2026

Dept 2018) or if any part of the building is occupied contrary to an existing certificate of

occupancy (see East Harlem MEC Parcel C, L.P. v Smalls, 82 Misc 3d 127[A], 2024 NY Slip Op

50317[U] [App Term, 1st Dept 2024]). It also applies irrespective of whether the unlawful

occupancy relates to the apartment at issue (see Smalls, 2024 NY Slip Op 51317[U], *1;

Ormonde Equities LLC v Jacoby, 81 Misc 3d 137[A], 2023 NY Slip Op 51416[U] [App Term,

1st Dept 2023]; West 48th Holdings LLC v Eliyahu, 64 Misc 3d 133[A], 2019 NY Slip Op

51066[U] [App Term, 1st Dept 2019]).

Here, respondent shows that HPD issued a violation on May 3, 2024 (No. 16946215),

which requires a certificate of occupancy to legalize an alteration on the 4th story of the building

whereby rooming units were combined. A similar violation (No. 12029073) was issued in 2017.

Upon the court taking judicial notice of the HPD website pursuant to MDL § 328(3), the court

finds that both violations remain open and uncertified as corrected. An open HPD violation is

prima facie evidence that the underlying condition is a hazard to life, health, or safety (see

Fiondella v 345 W. 70th Tenants Corp., 217 AD3d 495, 496 [1st Dept 2023]).

Respondent also annexes an OATH/ECB violation dated April 22, 2024 (No.

35243663P), which mirrors the HPD violations by referencing occupancy contrary to the

certificate of occupancy through the unlawful combining of rooming units on the 4th story of the

subject building. A penalty of $1,250.00 was imposed on petitioner as a result of the

OATH/ECB violation. Upon the court’s taking judicial notice of the NYC Department of

Buildings (DOB) website (see Kingsbrook Jewish Med. Ctr. v Allstate Ins. Co., 61 AD3d 13, 20

[2d Dept 2009]), the relevant OATH/ECB violation remains open with no compliance recorded.

The court also takes notice on the DOB website that no new certificate of occupancy was issued

3 of 5 [* 3] INDEX NO. LT-312360-25/NY FILED: NEW YORK CIVIL COURT - L&T 01/09/2026 05:18 PM NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 01/09/2026

for the subject building after the OATH/ECB violation. The only certificate of occupancy on file

dates to 1954. An OATH finding of occupancy contrary to the certificate of occupancy will

suffice as prima facie evidence in support of an MDL § 302 defense (see Jacoby, 2023 NY Slip

Op 51416[U], *1; see also Matter of GVS Props. LLC v Vargas, 172 AD3d 466 [1st Dept 2019]).

Thus, the court finds that respondent has established her prima facie burden on this

summary judgment motion. The court does not find that petitioner has come forth with

admissible evidence refuting respondent’s evidence that would create an issue of fact requiring a

trial on the merits. While counsel for petitioner stated during the argument that petitioner is

taking steps to remove the violations, which have been subject to bureaucratic delays, no proof

of this is annexed to the opposition papers; moreover, it is not for this court to nullify

administrative agency determinations (see Sohn v Calderon, 78 NY2d 755, 767 [1991]).

To the extent that petitioner argues that respondent should be barred from raising a

defense based on MDL § 302 because it was not raised in prior proceedings, the court finds this

argument to be unavailing.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Chazon, LLC v. Maugenest
971 N.E.2d 852 (New York Court of Appeals, 2012)
Alvarez v. Prospect Hospital
501 N.E.2d 572 (New York Court of Appeals, 1986)
Sohn v. Calderon
587 N.E.2d 807 (New York Court of Appeals, 1991)
Kingsbrook Jewish Medical Center v. Allstate Insurance
61 A.D.3d 13 (Appellate Division of the Supreme Court of New York, 2009)
Sima Realty L. L. C. v. Philips
282 A.D.2d 394 (Appellate Division of the Supreme Court of New York, 2001)
East Harlem MEC Parcel C, L.P. v. Smalls
2024 NY Slip Op 50317(U) (Appellate Terms of the Supreme Court of New York, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
2025 NY Slip Op 34948(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/usc-462-w-141-llc-v-richards-nycivctny-2026.