New York City landlords were devastated by the Court of Appeals' 2010 ruling in Grimm v. New York State Division of Housing and Community Renewal, 15 N.Y.3d 358, 912 N.Y.S.2d 491 (2010), a case involving the four-year look-back period for rent overcharge claims under the Rent Stabilization Law (RSL). In Grimm, the subject apartment was registered as rent stabilized in 1999 at a legal rent of $587.86. In 2000, the owner increased the rent to $2,000 per month, informing the incoming tenants that if they agreed to make certain repairs and improvements, the monthly rent would be only $1,450. The incoming tenants agreed to this arrangement.
In 2004, Sylvie Grimm moved into the apartment, also paying $1,450 per month. She filed a complaint of rent overcharge with DHCR in July of 2005, based on the owner's unusual arrangement with the prior tenants. DHCR dismissed the complaint, holding that the rent four years prior to the filing of Grimm's complaint was $1,450, and had not increased thereafter. The case eventually made its way to the Court of Appeals.
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