Amsterdam Realty Corp. v. Berman, 25 N.Y.2d 480 (1969)
A state statute providing for rent abatement for welfare tenants in buildings with hazardous violations does not violate equal protection, due process, or impair contractual rights, as it is a reasonable exercise of the state’s police power to address substandard housing.
Summary
This case examines the constitutionality of New York Social Welfare Law § 143-b, known as the Spiegel Law, which provides rent abatement for welfare tenants living in buildings with hazardous violations. The landlord, Amsterdam Realty Corp., challenged the law after eviction proceedings against welfare recipients for non-payment of rent were dismissed due to hazardous conditions in the building. The New York Court of Appeals upheld the law, finding it a valid exercise of the state’s police power to combat slum housing and not violative of equal protection, due process, or contractual rights. The court reasoned that the law was a reasonable measure to induce landlords to correct dangerous housing conditions, especially given the limited housing options available to welfare recipients.
Facts
Amsterdam Realty Corp. initiated eviction proceedings against three welfare recipients for non-payment of rent. The Welfare Department, acting as amicus curiae, argued that a hazardous condition in the building—a faulty, non-self-closing apartment door—rendered the building unsafe for all occupants. This violation of the building code was deemed a fire hazard. The trial court found the Spiegel Law constitutional and dismissed the eviction proceedings.
Procedural History
The Civil Court of the City of New York initially ruled in favor of the tenants, finding the Spiegel Law constitutional. The landlord appealed directly to the New York Court of Appeals under CPLR 5601, subd. (b), par. 2 due to the constitutional question involved.
Issue(s)
Whether Social Welfare Law § 143-b, providing rent abatement for welfare tenants in buildings with hazardous violations, violates: 1) the Equal Protection Clause; 2) the Due Process Clause; or 3) the Contract Clause of the U.S. Constitution.
Holding
1. No, because the law is based on a reasonable classification targeting landlords of welfare recipients, who have less incentive to make repairs due to guaranteed rent payments from public funds.
2. No, because the law provides implicit notice and a hearing to the landlord in the eviction proceeding.
3. No, because the law is a reasonable exercise of the state’s police power to address a legitimate public concern (substandard housing), and contracts are subject to the state’s power to regulate for the general welfare.
Court’s Reasoning
The Court of Appeals reasoned that the Spiegel Law did not violate the Equal Protection Clause because it targeted a class of landlords (