Landlords Barred From Suing Over Cuomo's Eviction Moratorium, McMahon Rules
"While it may be the case that governor has overstepped his authority under New York's Executive Law, curing those alleged harms would require this court to ignore the doctrine of state sovereign immunity and principles of federalism embodied in the Eleventh Amendment," wrote Chief Judge Colleen McMahon of the Southern District of New York.
June 29, 2020 at 06:15 PM
5 minute read
The original version of this story was published on New York Law Journal
A group of Westchester County landlords cannot sue in federal court to block Gov. Andrew Cuomo's temporary moratorium on evictions in response to the COVID-19 pandemic, a judge ruled Monday.
U.S. District Chief Judge Colleen McMahon of the Southern District of New York said in a 37-page opinion that federal courts do not have jurisdiction to determine whether Cuomo violated New York state law by enacting his May 7 executive order pausing evictions through Aug. 19.
In any event, she said, the order did not constitute a physical or regulatory taking by the government that would give rise to claims under the Fifth Amendment to the U.S. Constitution.
The lawsuit, filed in White Plains, sought to undo two provisions of the order, which temporarily blocked landlords from pursuing eviction proceedings and gave renters the option to put their security deposit toward their rent payment.
"In doing so, the order has given carte blanche to tenants to withhold rent without repercussion," attorney Mark A. Guterman of Lehrman, Lehrman & Guterman wrote in the May 27 complaint.
"Plaintiffs and all similarly situated landlords are precluded from asserting their rights and obtaining relief to protect their property, all the while remaining obligated to pay all of their own carrying costs and other expenses, including taxes to the various governmental divisions of New York state," Guterman argued.
In her ruling, McMahon noted that the U.S. death toll from the novel coronavirus had topped 120,000 as of Monday, making it the "deadliest pandemic in over a century." No country, she said, had suffered more than the U.S., and New York led all 50 states with nearly 400,000 cases and 25,000 deaths.
Cuomo's order built on a similar measure in March that barred all commercial and residential evictions through June but did not cancel rent payments altogether. Tenants are still responsible for making up any missed payments to their landlord, and the legislature has not passed any form of rent forgiveness to allay the concerns of renters when the payments come due.
The new order, however, did extend the original moratorium another two months for renters who qualified for unemployment benefits or were unable to pay rent due to economic hardships resulting from the pandemic. Under the order, landlords are also required to apply tenants' security deposits to unpaid rent at the request of renters, though the deposits must be repaid in increments starting 90 days after they are used.
McMahon ruled on cross-motions for summary judgment that federal courts do not have the power to address claims that Cuomo's order improperly and "effectively legislated new laws," in violation of the state's Executive Law and the New York Constitution.
"While it may be the case that governor has overstepped his authority under New York's Executive Law, curing those alleged harms would require this court to ignore the doctrine of state sovereign immunity and principles of federalism embodied in the Eleventh Amendment," she wrote.
With regard to the plaintiffs' takings claims, McMahon said that in times of emergency, state governments may reallocate economic hardships between private parties, like landlords and their tenants, without violating the Fifth Amendment.
The plaintiffs, she said, had failed to show that the state government had seized control of their properties, and the executive order was limited in its scope. Landlords, McMahon wrote, still had the ability to sue their tenants for back rent, and the order had neither reduced the amount owed nor had it forgiven any missed rent payments or other obligations.
"As long as the order is in place, tenants will continue to accrue arrearages, which the landlord will be able to collect with interest once the order has expired," McMahon wrote. "Furthermore, landlords will regain their ability to evict tenants once the order expires."
Reached by phone Monday evening, Guterman said McMahon's ruling missed the "practical realities" of the pandemic, where landlords were likely to end up "eating the money" that was owed to them from missed rent payments. He and his clients were still considering an appeal to the U.S. Court of Appeals for the Second Circuit or potentially bringing a separate challenge in state court.
"We respect the judge, and we appreciate the opportunities she gave us in the case to get our arguments out there," Guterman said.
"The more time that goes by, and the more money that goes by that's not paid, most tenants will probably want to walk away from it," he said. "No person, be it a landlord or anyone else, would want to be in a position of losing half of their income."
A representative from Cuomo's press shop did not respond Monday to a request for comment.
The case was captioned Elmsford Apartment Associates v. Cuomo.
Read More:
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllBaltimore City Govt., After Winning Opioid Jury Trial, Preparing to Demand an Additional $11B for Abatement Costs
3 minute readFederal Judge Sends Novel Damages Question in Employment Dispute to State Court
5 minute readCounty Reps: Appeal Likely Following State Court's Sales Tax Ruling for Retail Marijuana
6 minute readTrending Stories
- 1Senators Grill Visa, Mastercard Execs on Alleged Anti-Competitive Practices, Fees
- 2Deal Watch: Gibson Dunn, V&E, Kirkland Lead Big Energy Deals in Another Strong Week in Transactions
- 3Advisory Opinion Offers 'Road Map' for Judges Defending Against Campaign Attacks
- 4Commencement of Child Victims Act at Heart of Federal Question Posed to NY's Top Court
- 5Bolstering Southern California Presence, Sidley Austin Settles Into Revitalized Downtown LA Office
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250