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Village of Great Neck Plaza v. Nassau County Rent Guidelines Board

69 A.D.2d 528 (1979)

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Village of Great Neck Plaza v. Nassau County Rent Guidelines Board

New York Supreme Court, Appellate Division
69 A.D.2d 528 (1979)

DD

Facts

The Nassau County Rent Guidelines Board (the board) (defendant) was tasked with establishing annual guidelines for rent adjustments. The board had sole responsibility for determining the rent guidelines. The guidelines were administered and enforced by a state agency called the Division of Housing and Community Renewal (DHCR). The village of Great Neck Plaza (the village) (plaintiff) brought suit, contending that the board’s 1977–1978 rent guidelines violated the State Administrative Procedure Act (SAPA). The SAPA applied only to state agencies. The trial court found that the board was not a state agency and was thus not subject to the requirements of the SAPA. The village appealed.

Rule of Law

Issue

Holding and Reasoning (Mangano, J.)

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