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DOWDALL LAW OFFICES <br />A PROFESSIONAL CORPORATION <br />ATTO R N EYS AT LAW <br />City Council of the City of Santa Ana <br />City of Santa Ana <br />September 16, 2021 <br />Page 42 <br />money."" The practice is universally regarded as immoral and socially reprehensible. New York <br />criminalizes extractions of "key money" as a third degree misdemeanor." <br />The law, `designed to prevent the exploitation of those in desperate need of rental <br />accommodations', People v. Greenwald, 299 N.Y. 271, 86 N.E.2d 745, 746, is <br />aimed at the recipient of the bonus, not against the person who under stress yields <br />to the exaction. The one who pays is a victim, not a participant in the crime. <br />Gardner v. Miller, 2 Misc.2d 788, 788, 153 N.Y.S.2d 170, 171 (1956) (emphasis supplied). <br />The "victim" is the next generation tenant, the newcomer who needs affordable housing <br />but is locked out by high selling prices. `Monetizing' the rent -controlled lease at sale means that <br />the home is sold for much more than real value because a premium lease is included it is naked <br />key money. Yet "key money" is immoral, predatory and illegal.19 Even the Supreme Court has <br />acknowledged the widespread condemnation of "key money."20 "Key money" capitalizes rent <br />control benefits from the desperately needy.21 It exists to exploit a market which is already <br />" Stephen Malpezzi, Welfare Analysis of Rent Control with Side Payments: a Natural <br />Experiment in Cairo, Egypt, Regional Science and Urban Economics 28 (1998) 773-795. <br />" Mckinney's Consolidated Laws o fNew YorkAnnotated Currentness Penal Law § 180.55 <br />("A person is guilty of rent gouging in the third degree when, in connection with the leasing, rental <br />or use of real property, he solicits, accepts or agrees to acce t from a person some consideration of <br />value, less than two hundred fifty dollars, in addition to lawful rental and other lawful charges, a on <br />an agreement or understanding that the furnishing of such consideration will increase the possibility <br />that any person may obtain or renew the lease, rental or use of such property, or that a failure to <br />furnish it will decrease the possibility that any person may obtain or renew the same. ¶Rent gouging <br />in the third degree is a class B misdemeanor"). <br />" People v. Greenwald, 299 N.Y. 271, 281, 86 N.E.2d 745 747 (1949) ("While the fact <br />issue raised may in the abstract seem difficult, it is of a type with which the criminal courts are <br />entirely familiar, of a sort with which they are constantly called upon to deal. A similar issue is met <br />in the prosecution of a labor racketeer for extortion, when the defendant concedes receipt of the <br />alleged extortionate payment but claims that it was accepted in return for some legitimate service <br />to labor or management. Cf., e. People v. Parkinson, 297 N.Y. 749,77 N.E.2d 516; People v. Fay, <br />296 N.Y. 510, 68 N.E.2d 453'., <br />20 "Most apartment tenants do not sell anything to their successors (and are often <br />prohibited from charging "key money"), so a typical rent control statute will transfer wealth from <br />the landlord to the incumbent tenant and all future tenants." Yee v. City of Escondido, 112 S.Ct. <br />1522, 1530 (1992). <br />21 "hi apartment rent control, `key money' is typically paid to the landlord or her agent, <br />while in mobile home rent control the value of the regulated site rent is paid to the vacating tenant. <br />Analytically this makes no difference." Mason, Carl, & Quigley, John M., supra at 191, n.4. And <br />see, id. at 192 ("The tied sale of the coach together with the right to occupy a site is analytically <br />equivalent to the transfer of rental rights together with a payment of "key money' ` in apartment rent <br />control"). <br />-42- <br />