Campbell v. Blum

In Campbell v. Blum (91 AD2d 937 [1st Dept 1983]), plaintiffs sought a declaratory judgment that the proprietors of an adult home may not involuntarily evict a resident, except upon service of a 30-day written notice containing the alleged cause for eviction and commencement of a special proceeding in accordance with section 461-h of the Social Services Law. The Court held that legislation enacted subsequent to the commencement of the action, requiring due process prior to eviction, rendered the action moot (id.).