From Casetext: Smarter Legal Research

Firpi v. N.Y.C. Hous. Auth.

Supreme Court, Appellate Division, First Department, New York.
Jun 13, 2013
107 A.D.3d 523 (N.Y. App. Div. 2013)

Opinion

2013-06-13

In re Delilah FIRPI, Petitioner–Appellant, v. NEW YORK CITY HOUSING AUTHORITY, Respondent–Respondent.

Delilah Firpi, appellant pro se. Kelly D. MacNeal, New York (Seth E. Kramer of counsel), for respondent.



Delilah Firpi, appellant pro se. Kelly D. MacNeal, New York (Seth E. Kramer of counsel), for respondent.
TOM, J.P., MOSKOWITZ, RICHTER, MANZANET–DANIELS, CLARK, JJ.

Judgment, Supreme Court, New York County (Judith J. Gische, J.), entered November 29, 2011, denying the petition seeking to annul respondent's determination, dated December 22, 2010, which denied, after a hearing, petitioner's remaining family member (RFM) grievance, and dismissing this proceeding brought pursuant to CPLR article 78, unanimously vacated, the petition treated as one transferred to this Court for de novo review, and, upon such review, respondent's determination unanimously confirmed, the petition denied, and the proceeding dismissed, without costs.

Supreme Court treated the subject pro se petition as raising an issue of substantial evidence. Thus, the proceeding should have been transferred to this Court pursuant to CPLR 7804(g). Accordingly, we will treat the substantial evidence issue de novo and decide all issues as if the proceeding had been properly transferred ( see Matter of Filonuk v. Rhea, 84 A.D.3d 502, 502, 922 N.Y.S.2d 367 [1st Dept. 2011] ).

The determination denying petitioner succession rights is supported by substantial evidence ( Matter of Purdy v. Kreisberg, 47 N.Y.2d 354, 358, 418 N.Y.S.2d 329, 391 N.E.2d 1307 [1979] ). Petitioner conceded that her mother, the tenant of record, had never obtained respondent's written consent for her occupancy, and that she did not occupy the apartment for one year prior to her mother's death ( see Matter of Guzman v. New York City Hous. Auth., 85 A.D.3d 514, 925 N.Y.S.2d 59 [1st Dept. 2011] ). Although the denial of RFM status may present a hardship for petitioner and her family, mitigating factors do not provide a basis for annulling respondent's determination ( id.). Nor may estoppel be invoked against respondent ( see Matter of Parkview Assoc. v. City of New York, 71 N.Y.2d 274, 282, 525 N.Y.S.2d 176, 519 N.E.2d 1372 [1988],cert. denied488 U.S. 801, 109 S.Ct. 30, 102 L.Ed.2d 9 [1988];Matter of Kolarick v. Franco, 240 A.D.2d 204, 204, 658 N.Y.S.2d 295 [1st Dept. 1997] ).


Summaries of

Firpi v. N.Y.C. Hous. Auth.

Supreme Court, Appellate Division, First Department, New York.
Jun 13, 2013
107 A.D.3d 523 (N.Y. App. Div. 2013)
Case details for

Firpi v. N.Y.C. Hous. Auth.

Case Details

Full title:In re Delilah FIRPI, Petitioner–Appellant, v. NEW YORK CITY HOUSING…

Court:Supreme Court, Appellate Division, First Department, New York.

Date published: Jun 13, 2013

Citations

107 A.D.3d 523 (N.Y. App. Div. 2013)
967 N.Y.S.2d 352
2013 N.Y. Slip Op. 4451

Citing Cases

Rios v. N.Y.C. Hous. Auth.

Although the denial of remaining family member status may present a hardship for petitioner, mitigating…

Narvaez v. N.Y.C. Hous. Auth.

A person seeking to succeed to a lease in a NYCHA building as a remaining family member must show that she…