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
| Court | Appellate Division, First Department |
|---|---|
| Decided | October 6, 2026 |
| Citation | 2026 NY Slip Op 05728 |
| Area of law | Real Property |
| Week | Week ending October 10, 2026 |
| Official text | Official decision: 2026 NY Slip Op 05728 |
| Publication status | Slip opinions are uncorrected and subject to revision before publication in the Official Reports. |
| Source feed | New York slip opinion page |
| Law Watch record id | 950 |
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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