Security Deposit Vouchers Are a "Source of Income" Under NYC Law

LVT Number: #30855

Prospective tenant applied for an apartment from landlord, who rejected her application because she couldn't pay a cash security deposit. Tenant claimed that she had a security deposit voucher from HRA. Claiming that the city tried to force it to accept the voucher, landlord sued the city and sought a ruling that the "source of income" provisions of NYC's Human Rights Law didn't apply to HRA security vouchers. The city asked the court to dismiss the case. The court ruled for the city, finding that the HRA security voucher was a lawful source of income.

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Estates NY Real Estate Servs. LLC v. City of New York: Index No. 155991/18, 11012, 2020 NY Slip Op 03093 (App. Div. 1 Dept.; 5/28/20; Gische, JP, Kapnick, Webber, Moulton, JJ)