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Appellate Division, Second Department · October 21, 2026 · 2026 NY Slip Op 06154

Perkins v 34 215 St, LLC

Read the official decision: 2026 NY Slip Op 06154

Holding The court reversed the lower court’s denial of summary judgment, holding that the notary complied with statutory identity verification obligations and that the title company was not liable for negligence to a non-contracting party absent evidence of fraud or special circumstances.

The court’s words

Vitucci, in his capacity as the notary at the closing, complied with his statutory obligations to verify the identity of the parties

2026 NY Slip Op 06154, at the official text

title company hired by one party is not, absent evidence of fraud, collusion, or other special circumstances, subject to suit for negligent performance by one other than the party who contracted for its services

2026 NY Slip Op 06154, at the official text
CourtAppellate Division, Second Department
DecidedOctober 21, 2026
Citation2026 NY Slip Op 06154
Area of lawReal Property · Personal Injury and Negligence
WeekWeek ending October 24, 2026
Official textOfficial decision: 2026 NY Slip Op 06154
Publication statusSlip opinions are uncorrected and subject to revision before publication in the Official Reports.
Source feedNew York slip opinion page
Law Watch record id1419

Recommended citation

ESQ HQ, New York Law Watch, Perkins v 34 215 St, LLC, 2026 NY Slip Op 06154 (Appellate Division, Second Department, October 21, 2026), https://esqhq.com/decisions/2026-ny-slip-op-06154/

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 21, 2026. Updated October 21, 2026.