Elderly Landlord Has Duty to Clean

The DOS issued landlord a violation notice for not sweeping 18 inches into the street. The ALJ fined landlord $50, and she appealed. Landlord argued that she is 83 years old and wheelchair-bound, so she can't frequently sweep the sidewalk and gutter area. The ECB upheld the fine. Landlord's infirmity doesn't excuse her obligation to clean. If she can't do the work herself, she must arrange for someone else to do it.

City of New York v. Horn: ECB App. No. 19853 (6/29/94) [2-page document]