Mendel v. Henry Phipps Plaza West, Inc.

Summary

The New York Court of Appeals affirmed dismissal of tenants’ claims seeking to enforce third-party beneficiary rights under a land disposition agreement involving a Mitchell-Lama housing complex. The court held that the tenants failed to establish that the agreement was intended for their benefit, particularly because the agreement expressly negated enforcement by third parties. The court therefore concluded that the tenants lacked standing to pursue the action.

Holdings

1. The plaintiffs lacked standing because they failed to establish that the land disposition agreement was intended for their benefit, and section 505 of the agreement expressly negated an intent to permit enforcement by third parties such as the plaintiffs.

Questions Presented

1. Whether the tenant plaintiffs could establish standing as intended third-party beneficiaries of the land disposition agreement.
2. Whether the land disposition agreement required continued participation in the Mitchell-Lama program or otherwise supported the plaintiffs' requested reformation and enforcement claims.

Disposition

affirmed