Key Takeaway
Court denies stay in declaratory judgment action due to insufficient overlap between parties in separate proceedings under CPLR 2201.
Procedural motions can significantly impact the timeline and strategy of litigation. One common tactical move involves requesting a stay of proceedings when related litigation is pending elsewhere. However, courts don’t automatically grant such requests — they must evaluate whether the circumstances truly warrant delaying the current action.
The decision in Ingram v Miller illustrates how courts analyze motions to stay proceedings when a declaratory judgment action is pending in another case. Under CPLR 2201, courts have discretion to grant stays “in a proper case,” but this discretion isn’t unlimited. The key factor often becomes whether the parties and issues in the separate actions are sufficiently related to justify the delay.
Jason Tenenbaum’s Analysis:
Ingram v Miller, 2014 NY Slip Op 01296 (2d Dept. 2014)
“Except where otherwise prescribed by law, the court in which an action is pending may grant a stay of proceedings in a proper case, upon such terms as may be just” (CPLR 2201; see Morreale v Morreale, 84 AD3d 1187, 1188). Here, the Supreme Court did not improvidently exercise its discretion in denying the appellant’s motion to stay all proceedings in the subject actions pending resolution of an action commenced by a codefendant’s insurer seeking, among other things, a declaratory judgment regarding insurance coverage for the codefendant. The parties in the declaratory judgment action were not sufficiently identical to, or overlapping with, the parties in these actions to warrant a stay”
Key Takeaway
Courts will deny motions to stay proceedings when the parties in related actions don’t sufficiently overlap. Even when insurance coverage issues are being litigated separately, the lack of identical or substantially overlapping parties means the separate action won’t necessarily resolve the issues in the current case, making a stay inappropriate under CPLR 2201.
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Legal Update (February 2026): Since this 2014 post, CPLR 2201 and related procedural rules governing stays of proceedings may have been subject to amendments or judicial interpretation developments. Practitioners should verify current provisions regarding discretionary stays in declaratory judgment actions and review recent case law interpreting the “proper case” standard for stay motions.
