Landlord-Tenant—Succession—”No Bright Line Rule” For Determining the Date of Permanent Vacatur by Tenant

A LANDLORD COMMENCED a summary holdover proceeding, alleging that the tenant of record (tenant) “surrendered her rent-stabilized tenancy and that the license to occupy the apartment of remaining occupants has expired.” The tenant’s daughter asserted that she is entitled to succeed to her mother’s tenancy. The daughter alleged that she had lived in the apartment since she was two and a half years old. The landlord sought summary judgment.