Section 8 Tenant Evictions

On July 11, 2012, in Landlord-Tenant, by John A. Weber IV, ESQ.

Section 8 Tenant Evictions

SECTION 8 TENANT EVICTIONS

In order to evict Section 8 tenants, landlords must follow special procedures that apply uniquely to Section 8 tenancies. The process is more complicated and difficult than typical evictions, but landlords with good reasons for evicting tenants should not be discouraged.
Section 8 is a government program that subsidizes a portion of certain tenants’ rent. The program is administered by NYCHA, the New York City Housing Authority. People may qualify for Section 8 vouchers for a number of reasons. People with mental illnesses or physical disabilities, for example, may be eligible for Section 8 vouchers. Some Section 8 vouchers may be transferred, by the tenant, from residence to residence, while other vouchers remain with the rental unit. In either case, a portion of the rent will be paid by the government directly to the landlord. The tenant is only responsible for the portion of the rent that is not covered by the voucher. If the landlord seeks any part of the subsidy portion in the eviction action, then NYCHA must be joined as a party to the case.

In any Section 8 eviction, NYCHA as well as the tenant must be notified of the grounds for eviction before the landlord begins the case. Once NYCHA and the tenant are notified, the process the landlord will have to follow will depend on the grounds for eviction. If the tenant is being evicted for nonpayment of rent or holdover based on termination of a Section 8 voucher, then the landlord must send a certification stating the grounds for eviction to NYCHA and the tenant. (A “holdover” is when a landlord evicts a tenant that remains in a rental unit after the lease has expired, or because the tenant remains in the unit after violating lease terms. If the lease agreement is contingent upon the Section 8 voucher, then termination of the Section 8 voucher would give the landlord grounds for eviction. This would be a holdover based on termination of a Section 8 voucher.) The landlord can then request a certificate of non-objection from NYCHA. Section 8 tenants can only be evicted for “good cause” – such as creating an ongoing nuisance or violating the law, among other things. NYCHA must be assured that the tenant is being evicted for good cause. If NYCHA issues a certificate of non-objection, then the certification of grounds may be substituted for the allegations in the landlord’s petition. If NYCHA does not respond in a timely manner, the landlord can begin the case, but should include an allegation stating that NYCHA has not responded in the petition. NYCHA may object to the grounds for eviction in the certification. In this event, the case may still proceed, but NYCHA must be joined as a party to the case. After this, the case can proceed as a typical eviction action.

Each of these procedural requirements must occur within specified timelines, and there may always be special circumstances demanding other procedural actions. Section 8 evictions can be one of the more difficult areas of housing law. But if the grounds are there, eviction is an option.

Landlord Tenant Attorneys

If you have any questions about this, or other legal issues, please call the Law Firm of Vaughn, Weber & Prakope, PLLC at 516-858-2620 to schedule a free consultation.

Does landlord have a duty to mitigate damages if tenant breaches lease?

If you are a landlord in New York, you may – or may not – be responsible for mitigating damages that result from a breach of the lease.

Generally, a non-breaching party to a contract has a duty to mitigate damages resulting from another party’s breach of contract. For example, imagine that a construction company enters into a contract to buy building materials from a manufacturer. If the manufacturer breaches the contract by failing to provide the building materials, the construction company will not be able to complete the building, and may not be paid for the project. Under traditional contract rules, the construction company has a duty to attempt to acquire the materials from another manufacturer. The construction company may not sue the manufacturer for all of the money it lost as a consequence of failing to complete the project unless it at least made an effort to replace the materials, by, for example, buying the materials from another manufacturer. Even if successful in replacing the materials, the construction company may sue the manufacturer for any additional costs it took on in search of those replacement materials.

Landlord tenant law sometimes imposes a similar duty upon a landlord in the event that a tenant breaches a lease by, for instance, moving out before the end of the lease term. Many jurisdictions would require a landlord in this position to at least attempt to rent the property to another tenant. If successful, the landlord will have avoided some of the financial losses that would have occurred had the property remained vacant until the end of the lease term. However, in other jurisdictions, no such duty is imposed upon landlords. In those cases, if a tenant breaches a lease by moving out, a landlord may wait until the end of the lease term, and then sue the tenant for the entire amount of rent still outstanding under the lease, without making any attempt to find a replacement tenant.

What kind of jurisdiction is New York? Surprisingly, it is both. Although most courts agree that commercial landlords have no duty to mitigate their damages (that is, they have no duty to find replacement tenants), there is much disagreement – and confusion – between the courts about whether residential landlords have such a duty. For the foreseeable future – that is, until a higher court takes an unambiguous position on this issue – case law in the different counties determines whether the duty applies to any given landlord.

If you are a landlord or tenant, and have any questions about how the law applies to your property or lease, please feel free to call (516) 858-2620 to speak with a Landlord Tenant Attorney.

 

*Contributions to the research and preparation for this blog were made by Jason Mays, J.D.(awaiting admission in NYS)

Landlord Liability

On March 5, 2012, in Landlord-Tenant, Personal Injury, by Robbie L. Vaughn, Esq.

Landlord Liability

In a recent case involving landlord liability, Brathwaite v. New York City Hous. Auth., 2012 NY Slip Op 1422 – NY: Appellate Div., 2nd Dept. 2012, the Court ruled that The New York City Housing Authority (NYCHA) was not liable for injuries the plaintiff sustained when he was assaulted inside the apartment of his girlfriend.

The court acknowledges that landlords have a common-law duty to take minimal precautions to protect tenants and their guests from the reasonably foreseeable criminal conduct of third parties. However, the court finds that NYCHA was not the proximate cause of plaintiff’s injuries.

Here is part of the Court’s reasoning:

Moreover, and contrary to the plaintiff’s contention, both NYCHA and American established their prima facie entitlement to judgment as a matter of law by demonstrating that any negligence on their part was not a proximate cause of the injuries sustained by the plaintiff. The plaintiff claimed that security was inadequate because NYCHA and American failed to repair a broken lock on the entrance to the building. However, the plaintiff testified at his deposition that the two locks on the door to Patsy’s apartment were functioning on the day in question. He further testified that he did not know how Glenn entered the apartment prior to the assault, that he and Patsy may have left the door unlocked when they entered earlier that day, and that Glenn may have had a key in any event. There was no testimony or documentary evidence arising from the investigation of the incident which suggested that Glenn had forcibly entered the apartment, or that he gained access other than through the front door. Thus, even if Glenn entered the building of his own accord because of the inoperative lock, he could not have gained access to the interior of the apartment where the assault occurred unless, as had been done on prior occasions, a family member let him in, furnished him with a key, or left the door unlocked.

Mineola Personal Injury Attorneys

As always, The Law Firm of Vaughn, Weber & Prakope, PLLC is here to assist you with your Personal Injury or Landlord-tenant matters. Contact us at (516) 858-2620 to arrange a consultation.

Deciding between a Holdover and Nonpayment Petition

On January 5, 2012, in Landlord-Tenant, by John A. Weber IV, ESQ.

Holdover vs. Nonpayment Evictions

Deciding between holdover and nonpayment evictions.

Recently, we have had several situations arise where clients had to determine whether they would bring a Holdover vs. Nonpayment eviction against the tenant.  Now it is true that in most situations, there is really no choice.  The facts of the specific case dictate that there is only one option available.  It is not correct however to assume that there are never situations where a choice exists.  The final decision needs to be the result of strategic planning between attorney and client.

The one constant that must be taken into account when determining which type of action you will ultimately bring is the desired outcome.  The attorney’s job is to take the specific facts of the case and develop the plan to achieve the desired outcome.  Together, the attorney client team decides on the type of action to bring.   Together, they have taken into consideration the ultimate goals of the landlord, the governing laws, the trends of the court rulings, and the facts of the case.

As always, if you are having trouble deciding which type of action to bring, call the Law Firm of Vaughn, Weber & Prakope, PLLC at (516) 858-2620!

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