New York Court of Appeals
Manhattan Telecommunications Corporation v. H & A Locksmith, Inc., and Ariq Vanunu
May 30, 201321 N.Y.3d 200
Summary
The New York Court of Appeals held that a failure to file proof of the facts constituting the claim under CPLR 3215(f) is not a jurisdictional defect that renders a default judgment a nullity. Accordingly, the Court reversed the Appellate Division’s order and remitted the case for further consideration.