Cintron v. Calogero

In Cintron v. Calogero, 15 NY3d 347, 938 N.E.2d 931, 912 N.Y.S.2d 498 (2010), the Court of Appeals considered a scenario in which the landlord had sought to bar the consideration of any DHCR rent reduction orders that had been entered more than four years prior to the base rent date that the landlord asserted was operative. The Court of Appeals denied the landlord's application, finding that, because Rent Stabilization Law 26-514 mandates that DHCR rent reduction orders give rise to a "continuing obligation," it would "thwart the goals of the Legislature", to apply the four-year statute of limitations in a way so as to obviate the effect of such orders. (Id., at 355-356.)