Matter of Mantilla v. New York City Dept. of Hous. Preserv. & Dev.

Summary

The Court of Appeals affirmed the denial of succession rights to a Mitchell-Lama apartment because the agency had a rational basis to conclude that the petitioner failed to prove the apartment was his primary residence for the required one-year period. The court held that the agency reasonably weighed the limited and conflicting residency evidence, including two months of benefits correspondence, Florida records, and the absence of additional documentation. The court also held that the Appellate Division improperly relied on the petitioner's failure to submit tax returns because that ground was not invoked by the agency and therefore was outside the scope of judicial review.