March 26, 2015
Edison Med. Servs., P.C. v Clarendon Natl. Ins. Co. (2015 NY Slip Op 50479(U))
https://www.beynensonlaw.com/case-law/edison-med-servs-p-c-v-clarendon-natl-ins-co-2015-ny-slip-op50479u/
- Decided
- March 26, 2015
- Citation
- 2015 NY Slip Op 50479(U)
- Posture
- Default or vacatur
- Outcome
- Provider prevailed
- Issues
- Defaults and vacatur
- Legal questions
- Vacating a default: excuse and defense (see the maps)
Posture, outcome, issues and treatment by other decisions are Beynenson Law’s classification. Treatment labels are assigned by a language model reading the citing decision; negative and appeal-history labels are checked by a second reader.
Summary
Editorial summary by Beynenson Law, not part of the court’s decision.
Reported in New York Official Reports at Edison Med. Servs., P.C. v Clarendon Natl. Ins. Co. (2015 NY Slip Op 50479(U))
SUPREME COURT, APPELLATE TERM, SECOND DEPARTMENT, 2d, 11th and 13th JUDICIAL DISTRICTS
against
Clarendon National Insurance Company, Appellant.
Appeal from an order of the Civil Court of the City of New York, Kings County (Carol Ruth Feinman, J.), entered March 15, 2013. The order denied defendant’s motion to vacate a default judgment and, upon vacatur, to dismiss the action pursuant to CPLR 3215 (c).
ORDERED that the order is affirmed, without costs.
Plaintiff commenced this action to recover assigned first-party no-fault benefits, and the summons and complaint were personally served upon defendant’s authorized agent (see CPLR 311 [a] [1]) on March 13, 2007. It is undisputed that defendant did not answer the complaint and, thus, defaulted in the action on April 2, 2007 by failing to appear within 20 days after service of the summons (CCA 402 [a]). In November 2007, which was within one year of defendant’s default, plaintiff moved for leave to enter a default judgment. Defendant admitted receipt of the motion papers, which subsequently were rejected by the court. On April 17, 2008, plaintiff served a second motion for leave to enter a default judgment, and the Civil Court granted plaintiff’s motion on default. A default judgment awarding plaintiff the principal sum of $3,392.13 was entered on November 28, 2011. In April 2012, defendant moved to vacate the judgment and, upon vacatur, to dismiss the action, pursuant to CPLR 3215 (c), on the ground that plaintiff had failed to enter a default judgment within one year of defendant’s default. By order entered March 15, 2013, the Civil Court denied defendant’s motion, finding that defendant had failed to offer a reasonable excuse for not answering the complaint or a meritorious defense to the action.
CPLR 3215 (c) requires that a plaintiff commence proceedings for the entry of a default judgment within one year after the default. Where a plaintiff has made an application to the court for the entry of a default judgment within that period, the court may not later dismiss the complaint as abandoned pursuant to CPLR 3215 (c) (see U.S. Bank N.A. v Poku, 118 AD3d 980 [2014]; Jones v Fuentes, 103 AD3d 853 [2013]), even where, as here, the application was unsuccessful (see Brown v Rosedale Nurseries, 259 AD2d 256 [1999]). Furthermore, in the present case, as plaintiff filed the second motion for the entry of a default judgment, plaintiff demonstrated that it had not abandoned the action (see Jones, 103 AD3d 853; Brown, 259 AD2d [*2]256; see also Icon Equip. Distribs. v Gordon Envtl. & Mech. Corp., 272 AD2d 579 [2000]; Patterson v Patterson, 220 AD2d 731 [1995]). Consequently, defendant was not entitled to dismissal of the complaint.
With respect to the branch of defendant’s motion, pursuant to CPLR 5015 (a), to vacate the default judgment, which was entered upon an order that granted plaintiff’s unopposed motion, defendant was required to demonstrate both a reasonable excuse for the default and a potentially meritorious defense to the action (see CPLR 5015 [a] [1]; Eugene Di Lorenzo, Inc. v A.C. Dutton Lbr. Co., 67 NY2d 138 [1986]). Defendant’s sole excuse for failing to oppose plaintiff’s motion for entry of a default judgment was its denial of receipt of plaintiff’s motion, which excuse was insufficient to rebut the presumption of proper service that was raised by plaintiff’s affidavit of service (see Kihl v Pfeffer, 94 NY2d 118 [1999]; Engel v Lichterman, 62 NY2d 943 [1984]; Ortega v Trefz, 44 AD3d 916 [2007]; Oparaji v Citibank, N.A., 44 Misc 3d 25 [App Term, 2d, 11th & 13th Jud Dists 2014]). In addition, defendant did not explain its failure to appear or answer the complaint, or demonstrate the existence of a potentially meritorious defense to the action (see Giraldo v Weingarten, 81 AD3d 885 [2011]). We further note that defendant failed to proffer any excuse for its five-month delay in moving to vacate the default judgment (see Bethune v Prioleau, 82 AD3d 810 [2011]). Accordingly, the order is affirmed.
Weston, J.P., Solomon and Elliot, JJ., concur.
Decision Date: March 26, 2015
Legal questions
A question of no-fault law this decision rules on, from our Legal Questions pages. Bars count the decisions on the question by year and court, coloured by category; circles are this decision and the decisions on the question it cites or that cite it. Point at a bar or circle for details. The categories and summaries are Beynenson Law’s classification, made by a language model and checked by a second reading.
Did the defaulting party show a reasonable excuse (or lack of notice) and a potentially meritorious defense or claim?
This decision: Relief denied because the party showed neither a reasonable excuse nor a potentially meritorious defense or claim
Held the insurer's bare denial of receiving the default-judgment motion insufficient to rebut the affidavit of service, and found it neither explained its failure to answer nor showed a potentially meritorious defense.
Of the 170 decisions on this question in the Second Department courts and the Court of Appeals, 21 (this one included) are in the same category.
Similar decisions
- Edison Med. Servs., P.C. v Country-Wide Ins. Co. (2011 NY Slip Op 50193(U))The insurer failed to provide a reasonable excuse for its late answer and was denied vacatur of the default judgment.
- A.H. Physical Therapy, P.C. v 21st Century Advantage Ins. Co. (2021 NY Slip Op 21355)The insurer's detailed claims-clerk affidavit rebutted the process server's affidavit and required a traverse hearing on service.
- Grand Med. Supply Corp. v Permanent Gen. Assur. Corp. (2025 NY Slip Op 50491(U))The provider's complaint was dismissed as abandoned because it failed to timely seek a default judgment or justify its delay.
- Clinton Place Med., P.C. v Allstate Ins. Co. (2017 NY Slip Op 50400(U))The insurer's pattern of neglect did not warrant vacatur of the default judgment entered after it failed to oppose summary judgment.
- Atlantic Radiology Imaging, P.C. v Metropolitan Prop. & Cas. Ins. Co. (2016 NY Slip Op 50321(U))The provider failed to establish a reasonable excuse or potentially meritorious opposition when seeking vacatur of a default summary judgment order.