Matter of Murphy v. New York State Div. of Housing & Community Renewal

In Matter of Murphy v. New York State Div. of Housing & Community Renewal (21 NY3d 649 [2013]), the Court of Appeals found that it was arbitrary and capricious for a housing agency to deny succession rights based on the failure to follow the "strict" agency rules involving income affidavits. In doing so, the Court wisely departed from a long line of prior cases that upheld bright-line rules that ran athwart of the underlying purpose of such rules. The Court of Appeals also recognized that courts "must scrutinize administrative rules for genuine reasonableness and rationality in the specific context presented by a case" (id. at, 654-55.)