A New York court has ruled in a landlord-tenant dispute involving unpaid rent and the landlord's duty to mitigate damages. The case, Sheridan One Co., LLC v. Chowdhury, was decided on March 31, 2026, by Judge Eric J. Wursthorn in the Civil Court of the City of New York, Bronx County. The ruling affects both landlords and tenants in similar situations, clarifying the responsibilities of landlords when a tenant vacates a rental property.
The dispute began when Habibullah Chowdhury, the defendant, vacated his rent-stabilized apartment in April 2021, several months before the expiration of his lease. Chowdhury informed his landlord, Sheridan One Co., LLC, via email that he could no longer afford the rent due to financial difficulties caused by the COVID-19 pandemic. The landlord later claimed that Chowdhury owed unpaid rent and sought damages for property repairs, leading to the court case.
The court's decision centered on whether the landlord had fulfilled its obligation to mitigate damages after the tenant vacated the apartment. The case highlights the legal requirements for landlords in New York to minimize their losses when a tenant leaves a rental property before the lease term ends.
In the background of this case, Sheridan One Co., LLC is the owner of a multiple dwelling building located at 930 Sherman Avenue in the Bronx. Chowdhury had been a tenant since October 2010, with his most recent lease renewal obligating him to pay $1,494.23 per month until October 31, 2021. However, he vacated the apartment on April 30, 2021, and requested that his security deposit be applied to his final month’s rent.
After Chowdhury moved out, Sheridan One Co., LLC claimed he owed $9,715.38 for unpaid rent and property damages. The landlord's attorney presented evidence during a bench trial held on March 16, 2026, while Chowdhury represented himself. The court heard testimony from a collection administrator for the landlord and reviewed various documents, including the rent ledger and correspondence between the parties.
The court ruled that Chowdhury was liable for breaching the lease by not paying rent after he vacated the apartment. Judge Wursthorn stated, "Defendant breached the most recent renewal lease by failing to pay rent as of April 2021." However, the court also examined whether the landlord had taken adequate steps to mitigate its damages during the period following Chowdhury's departure.
The court found that Sheridan One Co., LLC failed to mitigate damages for the months of May, June, and July 2021. According to the ruling, the landlord did not provide sufficient evidence that it took reasonable and customary actions to re-rent the apartment during this time. Judge Wursthorn noted that the landlord's witness did not adequately explain the renovation work performed on the apartment and that the claim for damages was not substantiated.
However, the court determined that the landlord had fulfilled its duty to mitigate damages starting in August 2021. The apartment was relisted in August, and a new tenant signed a lease on September 20, 2021. The court awarded the landlord a total of $4,482.69 for unpaid rent from August through October 2021, plus interest.
This ruling has significant implications for both landlords and tenants in New York. It reinforces the requirement that landlords must actively seek to minimize their losses when a tenant vacates a rental property. The court's interpretation of Real Property Law § 227-e emphasizes that landlords have a duty to mitigate damages and cannot simply sit back and collect unpaid rent while allowing a property to remain vacant.
Moving forward, this case may influence similar disputes in New York and could serve as a reference point for landlords regarding their responsibilities under the law. It highlights the importance of documenting efforts to re-rent properties and maintaining clear communication with tenants.
As for what's next, it is unclear if there will be an appeal in this case. The court did not provide details on whether either party plans to challenge the ruling. However, the decision may prompt other tenants and landlords to review their lease agreements and understand their rights and obligations under New York law.