Corporate Landlord's Head Officer Can Be Named in Tenants' HP Proceeding

LVT Number: #30310

Tenants sued the building owner, its individual director, and the managing agent, seeking correction of Housing Maintenance Code (HMC) violations at the building. Tenants asked the court to direct several parties, including Steve Croman, as the individual who headed the owner entity, to correct the violations. Croman asked the court to dismiss the case as against him personally. He pointed out that a June 2018 consent decree governed management of the building, including correction of HPD violations. The court ruled against Croman.

Tenants sued the building owner, its individual director, and the managing agent, seeking correction of Housing Maintenance Code (HMC) violations at the building. Tenants asked the court to direct several parties, including Steve Croman, as the individual who headed the owner entity, to correct the violations. Croman asked the court to dismiss the case as against him personally. He pointed out that a June 2018 consent decree governed management of the building, including correction of HPD violations. The court ruled against Croman. Tenants pointed out that Croman was named as "head officer" of the building owner entity in HPD's multiple dwelling registration web page. The HMC defined an "owner" as any person directly or indirectly in control of a dwelling. Since the consent decree provided that Croman could sell the building, he was at least indirectly in control and could therefore be secondarily responsible for building maintenance, even though the building's management company was designated as primarily responsible in the decree. 

159 Stanton Tenants' Ass'n: Index No. 610/2019, NYLJ No. 1561925873 (Civ. Ct. NY; 6/19/19; Stoller, J)