239 East 115th Street HDFC v. Olunkunle

Summary

The court reversed an order denying a tenant’s motion concerning a settlement stipulation and remanded for a hearing to determine the parties’ intent regarding the ambiguous phrase “subject premises” and the applicable rent. It affirmed the denial of the tenant’s contempt motion because the stipulation and subsequent order did not contain a clear and unequivocal mandate requiring relocation to a one-bedroom apartment at a specified rent.

Holdings

1. The tenant's requested relief was not true reformation because he sought resolution of an ambiguity and enforcement of the stipulation according to his interpretation, rather than adding an omitted term or removing an inadvertently included term.
2. Because the stipulation was susceptible to more than one reasonable interpretation of the phrase "subject premises," it was ambiguous, requiring a hearing to determine the parties' intent and a new determination of the tenant's motion.
3. The contempt motion was properly denied because neither the stipulation nor the subsequent court order contained a clear and unequivocal mandate requiring the landlord to relocate the tenant to a one-bedroom apartment at a particular rent.

Questions Presented

1. Whether the tenant was entitled to reformation of the settlement stipulation based on alleged mutual mistake.
2. Whether the stipulation was ambiguous as to the meaning of the phrase "subject premises" and therefore required an evidentiary hearing regarding the parties' intent.
3. Whether the landlord could be held in contempt for failing to relocate the tenant to a one-bedroom apartment at the rent claimed by the tenant.

Disposition

reversed_and_remanded