Troy Ltd. v. Renna

In 1981, New Jersey enacted the Senior Citizens and Disabled Protected Tenancy Act to protect senior citizens and disabled people against eviction from housing that had been converted from rental housing to condominium ownership. Under the act, senior citizens meeting age requirements and disabled tenants were granted a 40-year protected-tenancy status, during which they could not be evicted from tenancies that had been converted into condominiums. However, a tenant with protected status could lose the status if she changed her principal place of residence, if her income level exceeded the statutorily determined amount, or on the basis of a recognized good cause for eviction. The act also contained a retroactivity clause that conferred discretion on courts to recognize protected tenancy status for individuals who would otherwise qualify for the status except that the rental dwelling was converted prior to the act taking effect. Troy, Ltd. (plaintiff) purchased an apartment complex in 1979 and filed a master condominium deed in 1981 to convert the complex into a condominium. Troy entered into an agreement with East Coast Condo Tech, Inc. (East Coast) (plaintiff) under which East Cost would own the apartment units and Troy would be the mortgagee of the units. The agreement closed one month before the act came into effect. Troy and East Coast filed an action seeking a declaratory judgment regarding the act’s applicability to the converted apartment complex and an injunction against any enforcement of the act to tenants in the complex. The lawsuit named tenants allegedly claiming benefits as senior citizens under the act as defendants (the tenants) (defendants). The court granted partial summary judgment for Troy and East Coast, holding that the retroactive application of the act violated the Takings Clause. The tenants appealed.