A landlord’s offer of a renewal lease with a 92 percent increase to a tenant in a Housing Development Fund Corporation, or HDFC, building is "unconscionable" and amounted to eviction without cause, a Manhattan Housing Court judge has ruled. HDFCs are subsidized, restricted-income housing cooperatives. Tenants residing in a building converted to an HDFC may choose to continue renting. Such tenants are not protected by the Rent-Stabilization Law, but they can be evicted only for cause.

One such tenant in a Harlem building, Lavord Hussein, had been paying $650 a month for close to 30 years when her landlord, 303 West 122nd Street HDFC, offered her a new rent of $1,250 last August. After she said she could not afford it and did not renew the lease, the landlord began a proceeding to take possession of the unit.