Matter of Park East Land Corp. v. Finkelstein, 299 N.Y. 70 (1949)

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An administrative agency’s interpretation of its own regulations is entitled to deference if the interpretation is reasonable and consistent with the underlying statute’s purpose, even if other interpretations are possible.

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Summary

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Park East Land Corp. sought permission to renovate an apartment, which was denied by the Rent Administrator. The core issue was whether a specific space qualified as a “room” under rent control regulations. The Court of Appeals reversed the Appellate Division, reinstating the Special Term’s judgment, thereby upholding the Administrator’s denial. The court emphasized that the Administrator’s interpretation of “room” was reasonable and within the scope of their delegated authority. The dissent argued that the court improperly substituted its judgment for the Administrator’s, ignoring the agency’s expertise and the legislative intent behind rent control.

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Facts

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Park East Land Corp. owned an apartment building and sought permission to renovate an apartment. The application was denied by the Rent Administrator. The specific dispute centered on whether a space enclosed by three walls and a door constituted a