Minjak Co. v. Randolph

Rule of Law:

A tenant may claim constructive eviction as a defense to nonpayment of rent even if they have only abandoned a portion of the premises made unusable by the landlord's actions. Punitive damages may be awarded for a breach of the warranty of habitability if the landlord's conduct demonstrates high moral culpability or criminal indifference to civil obligations.

Facts:

• In 1976, respondents Randolph and Kikuchi rented a loft from the petitioner landlord, using approximately two-thirds as a music studio and the remainder as their residence.
• Beginning in late 1977, the tenants endured at least 40 water leaks from a hot tub business operating on the floor above, damaging their property, including a grand piano.
• Starting in January 1978, sandblasting from the floor above caused sand to continuously seep into the tenants' loft, contaminating their clothes, food, and bed.
• The landlord repeatedly ignored the tenants' complaints regarding the water leaks and seeping sand.
• In September 1981, the landlord began major construction, which generated huge clouds of dust that poured into the loft, causing the tenants to suffer health problems like eye and sinus issues.
• The construction was performed in a dangerous manner, including demolishing stairs without warning signs, jackhammering a new entrance that dropped debris into the loft, and workers ripping down protective plastic sheeting the tenants had installed.
• From 1981 onward, due to the cumulative conditions, Kikuchi was completely unable to use the music studio portion of the loft.

Procedural Posture:

• The petitioner landlord initiated a summary nonpayment proceeding against the respondent tenants in the Civil Court of the City of New York.
• The tenants answered with affirmative defenses seeking a rent abatement and counterclaimed for breach of warranty of habitability, seeking both actual and punitive damages.
• A jury in the trial court found in favor of the tenants, awarding significant rent abatements based on constructive eviction and breach of warranty of habitability, along with $20,000 in punitive damages.
• Following the verdict, the trial court judge reduced the punitive damages award to $5,000 but otherwise upheld the verdict and awarded the tenants $5,000 in attorney's fees.
• The landlord, as appellant, appealed the judgment to the Appellate Term of the Supreme Court.
• The Appellate Term reversed the trial court's judgment, rejecting the partial constructive eviction defense because the tenants had not abandoned the entire premises, and struck the award of punitive damages.
• The tenants, as appellants, appealed the reversal to the Appellate Division of the Supreme Court, First Department.