Matter of Kasowitz, Benson, Torres & Friedman, LLP v. JPMorgan Chase Bank, N.A.

Summary

The Court of Appeals held that Chase, a lienholder that was not joined or required to intervene in an earlier action, was not precluded from challenging the legal basis of a fee judgment affecting its property interest. Chase's interest arose before the earlier action, and the judgment could not redefine that preexisting interest; moreover, notice and nonparty status did not satisfy due process because the prior litigant did not adequately represent Chase. The Court reversed and remitted for further proceedings.