In Martha Washington Tenants Association v. Roberts, 292 AD2d 225, 739 N.Y.S.2d 59 (1st Dept 2002), the First Department found that a tenants' association had standing to bring an Article 78 proceeding challenging an agency determination granting a certificate of no harassment to a hotel owner without a hearing where all the members of the association were tenants in the hotel owner's building.