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2018 NY Slip Op 28334

Citation
2018 NY Slip Op 28334
Jurisdiction
New York (state)
Source verification
cross_accepted_sealed

Full Text

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The evidence raises two issues as to the sufficiency of Brown's defense. First, were Brown's complaints made in good faith and second, assuming good faith, did MLR offer a credible non-retaliatory explanation for serving the notice to quit the tenancy upon Brown. A tenant is cloaked with the protection of Real Property Law § 223-b only if he makes "[a] good faith" complaint to a governmental authority (Real Property Law § 223-b [1] [a]). "[G]ood faith is an elusive idea, taking on different meanings and emphases as [courts] move from one context to another" (In re Hosking, 2016 WL 128209, *3, 2016 US Dist LEXIS 3492, *9 [SD NY, Jan. 11, 2016, 15 CV 3999 (VB)], citing Black's Law Dictionary [10th ed 2014]). It appears that no court has wrestled with the meaning of good faith in the context of Real Property Law § 223-b (1) (a). At an irreducible minimum, however, "good faith connotes an actual state of mind—a state of mind motivated by proper motive" (Polotti v Flemming, 277 F2d 864, 868 [2d Cir 1960] [internal quotation marks omitted], citing Doyle v Gordon, 158 NYS2d 248, 260 [Sup Ct, NY County 1954]).

In the context presented here, good faith has both an objective and subjective component. [*8]To establish the objective component, the tenant must prove that at the time he complained to governmental authorities, there was reasonable cause to believe that the landlord violated a health or safety law, regulation, code or ordinance. To establish the subjective component, the tenant must prove that his motivation for the complaint was based upon a sincere health and safety concern for himself, other tenants or the public.