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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

13315 Owners Corp. v. Kennedy, 4 Misc. 3d 931 (2004)

Citation
13315 Owners Corp. v. Kennedy, 4 Misc. 3d 931 (2004)
Parent Document
13315 Owners Corp. v. Kennedy, 4 Misc. 3d 931 (2004)
Jurisdiction
New York (state)
Effective Date
2004-06-29

Other Sections in This Document (76)

Full Text

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Under Pullman, therefore, courts should defer to a board’s vote as competent evidence that the shareholder-tenant’s conduct is objectionable under RPAPL 711 unless the shareholder-tenant makes a showing of one of the following: “[T]hat the board acted (1) outside the scope of its authority, (2) in a way that did not legitimately further the corporate purpose or (3) in bad faith.” (Pullman, 100 NY2d at 155.) When a shareholder-tenant successfully raises one of these defenses, the court can no longer assume that the shareholders and board members properly examined the competent evidence, and the court determines from its own evaluation of the competent evidence whether the cooperative is entitled to possession. (Warren A. Estis and William J. Robbins, Landlord-Tenant, Flying the Co-op, Business Judgment Rule Governs in Ending Tenancy, NYLJ, June 4, 2003, at 5, col 2.)