In Davidson 1992 Assoc. v. Corbett (190 Misc. 2d 813 [App. Term, 1st Dept 2002]), a private landlord brought a holdover proceeding against Elizabeth Corbett, an occupant in a section 8 project-based apartment. Corbett had commenced occupancy in the apartment as a home health care worker, and was identified as a "live-in attendant" on annual certification forms. The Appellate Term upheld the lower court's judgment awarding possession to the landlord. The court held that since the Department of Housing and Urban Development's regulations explicitly do not recognize care attendants for continued occupancy purposes, and since no approval was sought or obtained for Corbett to remain in the apartment as an additional family member, she was not entitled to succeed to the section 8 subsidy.