New York Court of Appeals
In the Matter of George Rizzo, Appellant v. New York State Division of Housing and Community Renewal, Respondent
December 20, 20056 N.Y.3d 104
Summary
The Court held that in an article 78 review of a DHCR certificate of eviction, a court may not remit the case for de novo review of events that occurred after the agency's final determination; additional evidence under §26‑411 is limited to facts existing before that determination.