Case Type

Non-payment

Housing Type

Other

Court

SUPREME COURT, APPELLATE TERM, SECOND DEPARTMENT

County

Kings County (Brooklyn)

L&T / Index / Case / Docket / Clerk's Number

2024-981 K C

Slip Opinion Number

2025 NY Slip Op 50846(U)

Petitioner

Tuesdai Family Irrevocable Living Trust By Aldric Freeman, Trustee

Respondent

Pete John Denver, Jr., Osy Kokelu Brian, "John" "Doe", "Jane" "Doe"

Judge

Toussaint, Wavny, P.J., Mundy, Marina, Cora, Ottley, Lisa, S.

Decision/Order Date

2025-05-16

Posture

Post-judgment Motion by Tenant

Disposition

Motion Granted for Landlord

Winner

Landlord Substantially Won

Synopsis

The landlord obtained a default judgment in a nonpayment proceeding. A tenant moved to vacate the default, claiming improper service, which the Civil Court rejected. However, the Civil Court, without finding a reasonable excuse for the default, vacated the judgment and sua sponte dismissed the petition based on the merits. The Appellate Term, Second Department, reversed, holding that vacating a default judgment under CPLR 5015(a)(1) requires both a reasonable excuse for the default and a meritorious defense. The Civil Court's failure to find a reasonable excuse rendered its vacatur an improvident exercise of discretion. The Appellate Term reinstated the default judgment for the landlord.

Keywords

Default Standard not Met; Improvident Exercise of Discretion

Share

COinS