ESQ HQNEW YORK LAW WATCH

Appellate Division, First Department · October 6, 2026 · 2026 NY Slip Op 05728

JPMorgan Chase Bank, N.A. v Parmesar

Read the official decision: 2026 NY Slip Op 05728

Holding The 2019 foreclosure action was untimely because the prior 2008 acceleration remained valid despite the 2008 action being a legal nullity. The 2019 dismissal was for lack of personal jurisdiction, precluding the application of savings provisions under CPLR 205(a) and 205-a.

The court’s words

the 2019 action underlying this appeal was therefore untimely

2026 NY Slip Op 05728, at the official text

the finding that the action was a legal nullity did not revoke, invalidate, or otherwise destroy the lender's express invocation of the contractual election to accelerate the debt

2026 NY Slip Op 05728, at the official text

the 2019 order constituted a dismissal for lack of personal jurisdiction, preventing plaintiff from reaping the benefits of the savings provisions set forth in CPLR 205(a) and CPLR 205-a

2026 NY Slip Op 05728, at the official text
CourtAppellate Division, First Department
DecidedOctober 6, 2026
Citation2026 NY Slip Op 05728
Area of lawReal Property
WeekWeek ending October 10, 2026
Official textOfficial decision: 2026 NY Slip Op 05728
Publication statusSlip opinions are uncorrected and subject to revision before publication in the Official Reports.
Source feedNew York slip opinion page
Law Watch record id950

Recommended citation

ESQ HQ, New York Law Watch, JPMorgan Chase Bank, N.A. v Parmesar, 2026 NY Slip Op 05728 (Appellate Division, First Department, October 6, 2026), https://esqhq.com/decisions/2026-ny-slip-op-05728/

How this record was made

Holding drafted by Law Watch’s in-house model, graded by three reviewers; every quotation verified word for word against the official text.

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Published October 6, 2026. Updated October 6, 2026.