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The Demise of the RRRA's Four-Year Statute

By Stewart E. Sterk
November 29, 2010

A central feature of the Rent Regulation Reform Act of 1997 (RRRA) was its prohibition, in any rent overcharge complaint, on examination of rental history more than four years old at the time the complaint was filed. In two recent decisions, Cintron v. Calogero, NYLJ 10/20/2010, p. 26., col. 1, and Grimm v. DHCR, NYLJ 10/20/2010, p. 26., col. 4., The Court of Appeals has eviscerated that prohibition, leaving it unclear when, if ever, a landlord may rely on the four-year statute.

The Statutory Provision

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