Tenant Wasn't Party to Landlord's Article 78 Proceeding

The DRA set tenant’s maximum collectible rent (MCR) based on building data for 2006-2007. Landlord appealed and lost. Landlord then filed an Article 78 court appeal, challenging the DHCR’s decision. The case was sent back for reconsideration and the DRA readjusted the MCR. Tenant then appealed and lost. Tenant argued that she should have been made a party to landlord’s court appeal. But landlord’s appeal was against the DHCR and the DHCR had to defend its order. Tenant didn’t have to be a party to the Article 78 proceeding. 

Yancey: DHCR Adm. Rev. Docket No. CV420017RT (9/15) [3-pg. doc.]