Key Takeaway
New York appellate court clarifies that procedural defects rarely constitute true jurisdictional defects under CPLR 5015(a)(4), making judgment vacatur extremely difficult.
Understanding Jurisdictional Defects in New York Civil Practice
When facing an unfavorable judgment, defendants often look for ways to challenge the court’s authority to render that decision. However, New York courts maintain strict standards about what constitutes a true “jurisdictional defect” that would warrant setting aside a judgment. The distinction between procedural errors and actual jurisdictional problems is crucial for practitioners to understand.
In civil litigation, jurisdictional challenges can arise in various forms, but courts are increasingly narrow in their interpretation of what qualifies as a defect serious enough to void a judgment. The procedural requirements for establishing proper jurisdiction are well-established, and mere technical violations rarely rise to the level of fundamental jurisdictional flaws.
Jason Tenenbaum’s Analysis:
Tribeca Lending Corp. v Bartlett, 2014 NY Slip Op 07429 (1st Dept. 2014)
The realm of procedural snafus that can trigger the existences of jurisdiction defects, sufficient to warrant 5015(a)(4) treatment are quite narrow. This case expresses this sentiment quite nicely.
“The alleged defects raised by defendant do not involve jurisdictional defects within the meaning of CPLR 5015(a)(4), and thus do not provide a basis for vacatur under that provision (Wells Fargo, N.A. v Levin, 101 AD3d 1519, 1521 , lv dismissed 21 NY3d 887 ; see Matapos Tech. Ltd. v Compania Andina de Comercio Ltda, 68 AD3d 672, 673 ; see also Varon v Ciervo, 170 AD2d 446, 447 ).”
The usual reminder is that it is quite difficult to get out of a judgment is resort is not made to 5015(a)(1)
Key Takeaway
This First Department decision reinforces that defendants cannot easily escape unfavorable judgments by claiming jurisdictional defects. Courts distinguish between true jurisdictional problems and mere procedural irregularities. Defendants seeking to vacate judgments should focus on CPLR 5015(a)(1) grounds rather than attempting to characterize procedural issues as jurisdictional defects.
Legal Update (February 2026): Since this post’s publication in 2014, New York courts have continued to refine the standards for jurisdictional defects under CPLR 5015(a)(4), with several appellate decisions further narrowing the scope of what constitutes a true jurisdictional defect versus procedural error. Additionally, there have been amendments to related Civil Practice Law and Rules provisions that may affect motion practice and procedural requirements. Practitioners should verify current case law interpretations and any regulatory updates when evaluating potential jurisdictional challenges.
