Rivera v. Correa

2025 NY Slip Op 30125(U)
CourtNew York Supreme Court, New York County
DecidedJanuary 14, 2025
DocketIndex No. 163058/2015
StatusUnpublished

This text of 2025 NY Slip Op 30125(U) (Rivera v. Correa) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rivera v. Correa, 2025 NY Slip Op 30125(U) (N.Y. Super. Ct. 2025).

Opinion

Rivera v Correa 2025 NY Slip Op 30125(U) January 14, 2025 Supreme Court, New York County Docket Number: Index No. 163058/2015 Judge: John J. Kelley Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 163058/2015 NYSCEF DOC. NO. 125 RECEIVED NYSCEF: 01/14/2025

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. JOHN J. KELLEY PART IAS MOTION 56EFM Justice --------------------------------------------------------------------------------X INDEX NO. 163058/2015 GUILLERMINA RIVERA, MOTION DATE 11/21/2024 Plaintiff, MOTION SEQ. NO. 005 -v- MICHAEL CORREA, M.D., MICHAEL CORREA, M.D., P.C., JEAN SALEH, M.D., JEAN W. SALEH, M.D., P.C., ST. LUKE’S DECISION AND ORDER ON ROOSEVELT HOSPITAL CENTER, and LENOX HILL HOSPITAL, MOTION Defendants.

---------------------------------------------------------------------------------X The following e-filed documents, listed by NYSCEF document number (Motion 005) 88, 89, 90, 91, 92, 93, 94, 95, 96, 106, 117, 119, 120, 121, 123

were read on this motion to/for DISMISS-CPLR 1021 .

This is an action to recover damages for medical malpractice. The defendants Jean

Saleh, M.D., Jean W. Saleh, M.D., P.C., and St. Luke’s Roosevelt Hospital Center (collectively

the St. Luke’s defendants) together move pursuant to CPLR 1021 to dismiss the complaint

insofar as asserted against them for the failure timely to substitute a representative of the

plaintiff’s estate in place and instead of the deceased plaintiff. The plaintiff’s nephew, Jose

Antonio Ortiz, opposes the motion. The motion is denied.

The plaintiff died on February 13, 2021, and her attorney notified the court of her death

on November 18, 2021. As the court explained it in an order dated November 18, 2021, the

death of a party divests a court of jurisdiction to conduct proceedings in an action until a proper

substitution had been made pursuant to CPLR 1015(a) (see Griffin v Manning, 36 AD3d 530,

532 [1st Dept 2007]; see also Perez v City of New York, 95 AD3d 675, 677 [1st Dept 2012];

Manto v Cerbone, 71 AD3d 1099 [2d Dept 2010]; Nieves v 331 E. 109th St. Corp., 112 AD2d

59, 60 [1st Dept 1985]). It further noted that any determination rendered or proceedings held

without such a substitution generally would have been deemed a nullity (see Griffin v Manning,

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36 AD3d at 532; Stancu v Cheon Hyang Oh, 74 AD3d 1322, 1322-1323 [2d Dept 2010];

Morrison v Budget Rent A Car Syst., Inc., 230 AD2d 253 [2d Dept 1997]; Nieves v 331 E. 109th

St. Corp.,112 AD2d at 60). Rather, the court further explained that the action was automatically

stayed upon the party’s death (see Perez v City of New York, 95 AD3d at 677), and that the

parties could not have “by agreement confer[red] subject matter jurisdiction upon the court

where there is none” (Cuomo v Long Island Lighting Co., 71 NY2d 349, 351 [1988]; see

Haverstraw Park, Inc. v Runcible Properties Corp., 33 NY2d 637 [1973]; Stancu v Cheon Hyang

Oh, 74 AD3d at 1323) by stipulating to conducting further proceedings prior to the substitution of

a personal representative for the deceased party. The court noted that any such stipulation

would be “legally inoperative” (Morrison v Budget Rent A Car Syst., Inc., 230 AD2d at 261).

On October 7, 2024, the St. Luke’s defendants made the instant motion pursuant to

CPLR 1021 to dismiss the complaint insofar as asserted against them (see CPLR 2211). CPLR

1021 provides, in relevant part, that

“[a] motion for substitution may be made by the successors or representatives of a party or by any party. If a person who should be substituted does not appear voluntarily he may be made a party defendant. If the event requiring substitution occurs before final judgment and substitution is not made within a reasonable time, the action may be dismissed as to the party for whom substitution should have been made, however, such dismissal shall not be on the merits unless the court shall so indicate”

The issue of what constitutes a reasonable time depends on the circumstances of the case (see

Randall v Two Bridges Assoc. Ltd. Partnership, 139 AD3d 435 [1st Dept 2016]), including the

diligence of the party who will ultimately seek substitution, the prejudice to the other parties, and

whether the party who eventually will be substituted has shown that the action has potential

merit (see Green v Maimonides Med. Ctr., 172 AD3d 824, 826 [2d Dept 2019]).

Although the St. Luke’s defendants waited three years and eight months after the

plaintiff’s death to make the instant motion, Ortiz---the person who seeks to be substituted as

the plaintiff herein---had already been deposed in this action, and had suffered a stroke after the

plaintiff’s death, rendering him temporarily incapable of petitioning the Surrogate’s Court for the

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issuance of letters of administration. He now asserts that he has recovered, and is ready,

willing, and able to seek the issuance of those letters, and to move to substitute himself as the

plaintiff herein. He thus has evinced no intention to abandon the action. The St. Luke’s

defendants have not established, under the circumstances of this case, that they waited a

“reasonable” time before moving to dismiss the complaint insofar as asserted against them,

despite what, on its face, might seem to constitute a “protracted” delay on Ortiz’s part in seeking

substitution, or that they would be prejudiced by the substitution (see Dugger v Conrad, 189

AD3d 478, 479-480 [1st Dept 2020]; Petion v New York City Health & Hosps. Corp., 175 AD3d

519, 520 [2d Dept 2019] [lapse of almost five years between plaintiff’s death and appointment of

representative of plaintiff’s estate, and additional lapse of one more year before representative

moved to be substituted, was insufficient to support defendant’s cross motion to dismiss

complaint pursuant to CPLR 1021 where it could not demonstrate prejudice]; Tokar v

Weissberg, 163 AD3d 1031, 1032-1033 [2d Dept 2018] [lapse of 2½ years between decedent’s

death and defendant’s submission of motion to dismiss under CPLR 1021 is insufficient to

support defendant’s contention that substitution had not been made within a reasonable time,

particularly where, as here, the case revolved around medical records already in defendant’s

possession]; see also Lee v Leeds, Morelli & Brown, P.C., _____AD3d_____, 2024 NY Slip Op

06624, *2-3 [2d Dept, Dec. 24, 2024] [despite the fact that the record did not establish diligence

in seeking substitution, “there has been no prejudice to the defendants”] cf. Kelly v St. Francis

Hosp., 100 AD3d 707, 708 [2d Dept 2012] [affirming dismissal of complaint where no attempt at

substitution was made during the three years following the plaintiff’s death]; Palmer v Selpan

Elec. Co., 5 AD3d 248, 248 [1st Dept 2004] [dismissing complaint where no substitution had

been effectuated for more than four years after the decedent’s death]).

Nonetheless, the court will not countenance any further delay. Hence, the denial of this

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Related

MATTER OF HAVERSTRAW PARK, INC. v. Runcible Props. Corp.
301 N.E.2d 553 (New York Court of Appeals, 1973)
Randall v. Two Bridges Associates Ltd. Partnership
139 A.D.3d 435 (Appellate Division of the Supreme Court of New York, 2016)
Cuomo v. Long Island Lighting Co.
520 N.E.2d 546 (New York Court of Appeals, 1988)
Palmer v. Selpan Electric Co.
5 A.D.3d 248 (Appellate Division of the Supreme Court of New York, 2004)
Griffin v. Manning
36 A.D.3d 530 (Appellate Division of the Supreme Court of New York, 2007)
Manto v. Cerbone
71 A.D.3d 1099 (Appellate Division of the Supreme Court of New York, 2010)
Stancu v. Cheon Hyang Oh
74 A.D.3d 1322 (Appellate Division of the Supreme Court of New York, 2010)
Perez v. City of New York
95 A.D.3d 675 (Appellate Division of the Supreme Court of New York, 2012)
Nieves v. 331 East 109th Street Corp.
112 A.D.2d 59 (Appellate Division of the Supreme Court of New York, 1985)
Morrison v. Budget Rent A Car Systems, Inc.
230 A.D.2d 253 (Appellate Division of the Supreme Court of New York, 1997)
Lee v. Leeds, Morelli & Brown, P.C.
2024 NY Slip Op 06624 (Appellate Division of the Supreme Court of New York, 2024)

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2025 NY Slip Op 30125(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/rivera-v-correa-nysupctnewyork-2025.