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6 Crannell St., LLC v. Urban Green Equities, LLC

Citation: 2022 NY Slip Op 04613Docket: 2021-04687

Court: Appellate Division of the Supreme Court of the State of New York; July 20, 2022; New York; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

This case involves an appeal by Urban Green Equities, LLC against a default judgment entered by the Supreme Court of New York, concerning a failure to respond to a complaint regarding real estate transactions. The plaintiffs, 6 Crannell St. LLC, sought to retain down payments and additional damages for breach of a sales agreement. Following the default judgment on February 17, 2021, due to the defendant's non-appearance, Urban Green Equities filed motions to vacate the judgment. The initial motion was denied without prejudice, but upon renewal, the court granted the motion on June 23, 2021. The court, applying CPLR 5015(a), required a reasonable excuse for the default and a potentially meritorious defense to vacate the judgment. Urban Green Equities demonstrated a reasonable excuse by highlighting a brief, six-day delay and lack of willfulness, and presented evidence suggesting the plaintiffs breached the agreement, constituting a potentially meritorious defense. The Appellate Division affirmed the vacating of the judgment, emphasizing the court's discretion and the importance of adjudicating cases on their merits, noting the plaintiffs were not prejudiced by the decision.

Legal Issues Addressed

Default Judgment under CPLR 5015(a)

Application: The court considered the requirements for vacating a default judgment, including a reasonable excuse for the default and a potentially meritorious defense.

Reasoning: The court found that to vacate a default judgment under CPLR 5015(a), a defendant must demonstrate a reasonable excuse for the default and present a potentially meritorious defense.

Discretion of Courts in Vacating Judgments

Application: The Appellate Division affirmed the lower court's exercise of discretion in vacating the default judgment, emphasizing the importance of resolving cases on their merits.

Reasoning: Ultimately, the Appellate Division affirmed the lower court's decision, emphasizing the importance of resolving cases on their merits and the absence of prejudice to the plaintiffs.

Meritorious Defense Requirement

Application: Evidence that the plaintiffs were in breach of the sales agreement supported the defendant's potentially meritorious defense.

Reasoning: Additionally, the defendant presented evidence suggesting the plaintiffs were in breach of the sales agreement, which supported a potentially meritorious defense.

Reasonable Excuse for Default

Application: The defendant's six-day delay and lack of willfulness constituted a reasonable excuse for the default, justifying the vacating of the default judgment.

Reasoning: The court noted that the defendant provided a reasonable excuse, highlighting a brief six-day delay in responding and a lack of willfulness.