In the Matter of Sylvie Grimm v. State of New York Division of Housing and Community Renewal Office of Rent…

Summary

The New York Court of Appeals affirmed the Appellate Division, holding that the DHCR must investigate alleged fraud and may not rely on the base‑date rent when the rent records are potentially unreliable; the court applied the rationale from Thornton v. Baron to this fraud context. Justice Smith dissented, arguing that the majority improperly erodes the statutory four‑year limitation.