The Housing Stability and Tenant Protection Act of 2019 (HSTPA), effective as of June 14, 2019, made significant changes to both the rent laws and the laws governing landlord-tenant proceedings in New York State. Among the many significant changes, Part I, §2, which amended Administrative Code of the City of New York § 26-511[c][9][b], provides that no rent stabilization code can be enacted unless it provides that no owner may refuse to renew a lease except: “where he or she seeks to recover possession of one dwelling unit because of immediate and compelling necessity for his or her own personal use and occupancy as his or her primary residence or for the use and occupancy of a member of his or her immediate family as his or her primary residence, provided, however, that this subparagraph shall permit recovery of only one dwelling unit” (emphasis supplied).

This section of the Administrative Code had previously provided that an owner could refuse to renew a lease “where he or she seeks to recover possession of one or more dwelling units for his or her own personal use and occupancy as his or her primary residence (emphasis supplied)” and/or for the use or occupancy of a member of his or her immediate family as his or her primary residence.

‘Fried v. Galindo’