Lefferts Ave. Ventures LLC v. Keennlyside

The court addressed a tenant's motion to dismiss a landlord's action for unpaid rent arrears, arguing a three-year statute of limitations for consumer credit transactions under CPLR 214-i. The tenant contended that unpaid rent constituted a consumer credit transaction. The court, however, rejected this argument, distinguishing it from consumer debt under the FDCPA. It ruled that failure to pay rent is a breach of a lease agreement, subject to a six-year statute of limitations for breach of contract, not a consumer credit transaction. Therefore, the tenant's motion to dismiss was denied, allowing the landlord's claim to proceed.