Does Rent-Stabilized Tenant's Daughter Have Succession Rights?

Landlord sued to evict rent-stabilized tenant for nonprimary residence. Tenant opposed landlord's claim. Alternatively, tenant's daughter claimed succession rights. Landlord asked the court to rule on tenant's nonprimary residence without trial. The court ruled for landlord. Tenant didn't dispute that he moved out of the apartment in October 2013. Landlord and tenant's daughter also asked the court to rule without trial on the question of the daughter's succession rights. The court found that a trial was needed. Tenant signed one renewal lease after he moved out in October 2013. Any claimed misrepresentation that he continued to reside in the apartment was made during this one term. The court found no intent to mislead landlord. But tenant's daughter needed to present proof at trial that she co-occupied the apartment with tenant during the two years between October 2011 and October 2013. 

Park Central I LLC v. Figueroa: Index No. 25249/2017, 2019 NY Slip Op 29185 (Civ. Ct. Bronx; 6/19/19; Bacdayan, J)