Appellate Term, Second Department · September 18, 2026 · 2026 NY Slip Op 51586[U]
Kings Ct. Hous., LLC v Dehoney
Read the official decision: 2026 NY Slip Op 51586[U]
Holding The Appellate Term reversed the lower court’s denial of the tenant’s motion to vacate a default judgment in a nonpayment proceeding. The court found the rent demand facially insufficient because it relied on an unexplained and confusing ledger, failing to fairly apprise the tenant of the rent owed.
The court’s words
A default final judgment may not be entered upon facially insufficient papers
2026 NY Slip Op 51586[U], at the official text
A proper rent demand is a statutory prerequisite to a nonpayment proceeding
2026 NY Slip Op 51586[U], at the official text
A rent demand must set forth the approximate good faith amount of rent owed
2026 NY Slip Op 51586[U], at the official text
fairly apprise the tenant of the periods for which rent is allegedly due and in what amounts
2026 NY Slip Op 51586[U], at the official text
the rent demand here is based upon arrears of $4,832 without further explanation other than to reference the utterly confusing rent ledger described above
2026 NY Slip Op 51586[U], at the official text
| Court | Appellate Term, Second Department |
|---|---|
| Decided | September 18, 2026 |
| Citation | 2026 NY Slip Op 51586[U] |
| Area of law | Landlord and Tenant and Housing |
| Week | Week ending September 19, 2026 |
| Official text | Official decision: 2026 NY Slip Op 51586[U] |
| Publication status | Slip opinions are uncorrected and subject to revision before publication in the Official Reports. |
| Source feed | New York slip opinion page |
| Law Watch record id | 918 |
Recommended citation
ESQ HQ, New York Law Watch, Kings Ct. Hous., LLC v Dehoney, 2026 NY Slip Op 51586[U] (Appellate Term, Second Department, September 18, 2026), https://esqhq.com/decisions/2026-ny-slip-op-51586-u/
How this record was made
Holding drafted by Law Watch’s in-house model, graded by three reviewers; every quotation verified word for word against the official text.
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