Miracle Temple Apostolic Holiness Church of Am., Inc. v Mack and Heward

In this holdover proceeding, the landlord sought to evict month-to-month tenants based on a 90-day notice, claiming exemption from the Good Cause Eviction Law (GCEL) under RPL § 214(14) as a religious institution. The tenants moved to dismiss, arguing the landlord failed to state a cause of action. The court interpreted RPL § 214(14) to require current use of the premises by the religious facility, not merely future intent to house missionaries. Finding that the landlord's current use was only for rental purposes and the unit was not tax-exempt or currently affiliated with the church, the court granted the tenants' motion, dismissing the proceeding without prejudice for failure to state a cause of action and facts under RPAPL § 741(4).