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
| Court | Appellate Division, Second Department |
|---|---|
| Decided | October 21, 2026 |
| Citation | 2026 NY Slip Op 06154 |
| Area of law | Real Property · Personal Injury and Negligence |
| Week | Week ending October 24, 2026 |
| Official text | Official decision: 2026 NY Slip Op 06154 |
| 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 | 1419 |
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.
Read how Law Watch works