Tenant's Licensee Can't Sue Landlord for Illegal Lockout

Apartment occupant sued landlord, claiming that she had been illegally locked out of an apartment. The court ruled against occupant, who appealed and lost. Occupant was a Section 8 tenant of another apartment in a different building and presented no proof showing that she had a possessory interest in the apartment she was locked out of. She was merely a licensee of that apartment's tenant, didn't have "possession" of the apartment, and therefore can't maintain an unlawful entry and detainer proceeding against landlord.

Padilla v. Rodriguez: 61 Misc.3d 133(A), 2018 NY Slip Op 51471(U) (App. T. 1 Dept.; 10/19/18; Shulman, PJ, Gonzalez, Edmead, JJ)