A solo practitioner representing tenants in a rent nonpayment dispute has been sanctioned for bringing a “grossly frivolous” disqualification action against a Manhattan Housing Court judge.

Supreme Court Justice Herman Cahn said in Kyle v. Lebovits, 110838/07, that the “numerous factual and legal misrepresentations” in the case, the disrespect directed at Housing Court judges and the tenants’ “obvious intent to delay the resolution of the underlying … proceeding” all constituted frivolous conduct.