SERVICE OF PROCESS AND PERSONAL JURISDICTION

SUBSTITUTED SERVICE UNDER CPLR 308(2) IN CIVIL ACTIONS AND UNDER RPAPL 735(1) IN SUMMARY PROCEEDINGS: A COMPARATIVE ANALYSIS, WITH SOME OBSERVATIONS ON SERVICE UNDER FAMILY COURT ACT SECTION 427(a)

PART 1 of 3

By David Calender, Esq., Attorney at Law

Founder and Chief Executive Officer, New York Case -Winning Strategies, LLC

 

The New York civil practitioner is, presumably, thoroughly conversant with the hornbook rule that, in order for a court to exercise personal jurisdiction over a defendant in a civil action (in summary Landlord-Tenant proceedings, a “respondent”), the defendant must be properly served with process (in the typical civil case, a Summons; in Family Court proceedings, a Summons and Petition; in Summary landlord-tenant proceedings, a Notice of Petition and Petition).

Service of process by substituted service, specifically the method commonly referred to as “deliver-and-mail” service, is authorized by subdivision (2) of Section 308 of the Civil Practice Law and Rules (“CPLR 308(2)”) in a civil case and by Section 735(1) of the Real Property Actions and Proceedings Law (“RPAPL 735(1)”) in Summary proceedings.

However, these statutory provisions must be understood and deployed with a clear understanding that, notwithstanding the appearance at first blush that they contain identical, interchangeable provisions, there is a subtle but crucial distinction between the two: the method provided by RPAPL Section 735(1) for deliver-and-mail substituted service is narrower in the scope of its application and, consequently, presents a pitfall for the unwary petitioner in a Summary proceeding, whereas service pursuant to CPLR 308(2) under similar circumstances is routinely sustained by the courts as valid. For the reasons discussed below, the practitioner in Landlord-Tenant proceedings is advised to proceed with caution when effecting deliver-and-mail service upon a tenant pursuant to RPAPL 735(1).

Failure by the litigant in summary landlord-tenant proceedings to appreciate the practical distinction between these two provisions has resulted in dismissal of many a Summary proceeding on personal jurisdictional grounds -- often after much time, effort and expense have been invested in procuring a Judgment of Possession and/or Money Judgment for rent owed, thus forcing the anguished petitioner landlord to resort to recommencing the proceeding ab initio.  It is hoped that the reader will benefit from this article’s comparative analysis of some notable cases that illustrate the difference in application in the real world of these discrete categories of deliver-and-mail substituted service.

Where the defendant in a civil action is an individual (a “natural person”), Section 308 of the CPLR provides that personal service may be made by delivering the legal process: (i) directly to the defendant (CPLR 308(1)); (ii) to someone of suitable age and discretion at the defendant’s “actual place of business, dwelling place or usual place of abode” and mailing a copy of the summons to the defendant’s last known residence or actual place of business” (CPLR 308(2)); (iii) to an agent designated under CPLR 318 (CPLR 308(3)); and (iv) where, notwithstanding diligent, but unsuccessful, efforts to effect service pursuant to CPLR 308(1) and CPLR 308(2), by affixing the process to the door of the defendant’s “actual place of business, dwelling place or usual place of abode within the state” And mailing a copy of the summons to the defendant at his/her actual place of business or last known residence (CPLR 308(4)).

Scope and Operation of CPLR 308(2) in Civil Actions Generally (Except Divorce)

The provisions of CPLR 308(2), implicated in this article, provides for the following method of deliver-and-mail substituted service:

Section 308. Personal service upon a natural person

Personal service upon a natural person shall be made by any of the following methods: . . .

2.  by delivering the summons within the state to a person of suitable age and discretion at the actual place of business, dwelling place or usual place of abode of the person to be served and by either mailing the summons to the person to be served at his or her last known residence or by mailing the summons by first class mail to the person to be served at his or her actual place of business in an envelope bearing the legend “personal and confidential” and not indicating on the outside thereof, by return address or otherwise, that the communication is from an attorney or concerns and action against the person to be served, such delivery and mailing to be effected within twenty days of each other; proof of such service Shall be filed with the clerk of the court designated in the summons within twenty days of either such delivery or mailing, whichever is effected later; service shall be complete ten days after such filing; proof of service shall identify such person of suitable age and discretion and state the date, time and place of service . . .

Thus, pursuant to CPLR 308(2), the process to be served need only be delivered to “a person of suitable age and discretion at the actual place of business, dwelling place or usual place of abode of the person to be served” See, e.g., Bank of New York v. Espejo, 92 A.D.3d 707, 708 (2nd Dept. 2012) (holding that “[valid] service pursuant to CPLR 308(2) may be made by delivery of the summons and complaint to a person of suitable age and discretion who answers the door at the defendant’s residence, but is not [necessarily] a resident of the subject property”).

In Espejo, an action to foreclosure a mortgage, the defendants were served pursuant to CPLR 308(2) with copies of the summons and complaint at their home by delivery of a copy of the summons and complaint to one Michael Guzman, referred to in the affidavit of service as a cotenant, and by mailing two additional copies of the summons and complaint to the defendants at the same address. The defendants did not respond to the summons and complaint and a default judgment of foreclosure and sale was entered against them. Some eight months later, the defendants moved to vacate the judgment entered upon their default. Insofar as relevant to this article, in support of the motion challenging the validity of service, one defendant submitted an affidavit stating that she was not validly served with a copy of the summons and complaint because Michael Guzman, who received service, did not reside at the property where service was effected. The Supreme Court, Kings County, denied her motion to invalidate service on this ground and an appeal ensued.  

On appeal, the Appellate Division, Second Department, affirmed the denial of the motion challenging the validity of service, holding that, notwithstanding the defendant’s sworn statement that Michael Guzman did not reside at the property where the process was served,

[v]alid service pursuant to CPLR 308(2) may be made by delivery of the summons and complaint to a person of suitable age and discretion who answers at the door at a defendant’s residence, but is not a resident of the property.

In support of this conclusion, the Appellate Division, Second Department, cited a pair of its previous decisions, one in the context of an action to recover a real estate broker’s commission (U.S. 1 Brookville Real Estate Corp. v. Spallone, 21 A.D.3d 480. 481-482 (2005)) and the other in the context of an action to recover damages for personal injuries (Chesman v. Lippoth, 271 A.D.2d 567 (2000)).

            Thus, the law in New York is by now well-settled that, under CPLR 308(2), assuming that the prescribed follow-up mailing and filing with the court is completed, the requirement of deliver-and-mail substituted service is satisfied merely by delivering the summons to any individual of suitable age and discretion who answers the door at the defendant’s residence (described by the statute as defendant’s “dwelling place or usual place of abode”), even if such person is not a resident of the premises. For this reason, the trial court and the Appellate Division rejected the argument by the defendant in Espejo, supra, that service was invalid because Michael Guzman did not reside at the home where he answered the door and took delivery of the Summons.

That said, an important procedural question arises: What if the facts are identical, except that the legal document handed to the person who answers the door is not a Summons (in a mortgage foreclosure or breach of contract or personal injury action), but rather a Notice of Petition in a Summary Proceeding to recover possession of real property and/or to recover rent arrears?   Would the analysis in the three cited decisions of the Appellate Division, Second Department, apply to invalidate service of process under the same circumstances in a Summary proceeding? (Parenthetically, appeals lie from the Landlord-Tenant Court to the Appellate Term of the Supreme Court, comprising a panel of sitting Justices of the Supreme Court, not the Appellate Division.)

This is Part 1 of a 3-Part article on the “deliver-and-mail” method of substituted service in New York Civil Practice. In Part 2, we will compare and contrast the methods of deliver-and-mail service provided for in CPLR 308(2) and RPAPL 735(1), respectively, focusing on a review of the statutory provisions governing deliver-and-mail service in the context of Summary Landlord-Tenant proceedings – and the case law relating thereto – which we think the practitioner and process server alike will find illuminating.

#personaljurisdiction

#serviceofprocess

#substituted service

#cplr308

#rpapl735

#fca427

#foreclosure

#evictions

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