Guttenberg S. & L. Ass'n. v. Rivera

In Guttenberg S. & L. Ass'n. v. Rivera, 85 N.J. 617, 626-27, 428 A.2d 1289 (1981), the Supreme Court of New Jersey held that a foreclosing mortgagee of a residential apartment building may obtain an order of eviction under leases that are subordinate to the mortgage without complying with the Anti-Eviction Act, N.J.S.A. 2A:18-61.1 to -61.12, since the Anti-Eviction Act applies only to traditional landlord-tenant relationships and not to that of a mortgagee holding a lien prior to the lease of the tenant in possession. Guttenberg, supra, 85 N.J. at 623-25, 428 A.2d 1289.