153 Valentine LLC v Hawkins

In this post-foreclosure holdover, the landlord sought possession of a condominium unit from an occupant who was not a tenant. The landlord acquired title through a referee's deed after a foreclosure sale. The occupant argued the foreclosure was a legal nullity, rendering the landlord's title invalid, and also raised defenses of defective service, retaliatory eviction, and harassment. The court rejected the occupant's standing challenge, finding the foreclosure judgment and deed valid, as the prior court's "nullity" finding was limited and did not vacate the judgment. The court granted the landlord's motion for summary judgment and a judgment of possession, striking the occupant's defenses for lack of merit, noting retaliatory eviction does not apply to non-tenants and notes on a door do not constitute harassment.