Landlord not responsible for more than four years of overcharged rent. On August 16, 2018, the Appellate Division for the First Department held that the landlord for 27 West 96th Street in Manhattan did not engage in a fraudulent scheme to evade the Rent Stabilization Law and therefore the New York State Division of Housing and Community Renewal (DHCR) had miscalculated the amount of overcharged rent that was due back to tenants.