Warped Kitchen Floor and Other Conditions Weren't Minor

Rent-stabilized tenant complained of a reduction in services. The DRA ruled for tenant and reduced her rent, finding that the kitchen floor was warped, that the living room ceiling ledge needed to be plastered, sanded, and painted after unworkmanlike repairs had been made, and that the insides of two hallway closets needed to be painted. Landlord appealed and lost, claiming that the three services found not maintained were de minimis--that is, minor--and didn't warrant rent reduction. Landlord also argued that the kitchen floor wasn't warped and didn't create a tripping hazard. De minimis conditions are those that have minimal impact on tenants, aren't health hazards, don't affect the use and enjoyment of an apartment, and may exist despite regular maintenance of services. Here, inspection confirmed tenant's complaints and landlord didn't claim before the DRA that the conditions were minor. 

Levin/Samson Management LLC: DHCR Adm. Rev. Docket No. EX710037RO (9/15/17) [3-pg. doc.]