Appellate Term, Second Department · June 12, 2026 · 2026 NY Slip Op 51299[U]
Cooper v Apostolic Gospel Church of Christ, Inc.
Read the official decision: 2026 NY Slip Op 51299[U]
Holding The court affirmed the denial of the plaintiff’s motion to set aside a small claims judgment, determining that the motion was untimely under CPLR 4405 and failed to demonstrate good cause for the delay. The court also clarified that CPLR 2221 does not permit reargument of a decision after trial.
The court’s words
CPLR 2221 does not permit reargument of a decision after trial and is limited to review of a court's ruling on a prior motion
2026 NY Slip Op 51299[U], at the official text
was untimely as it was not made within 15 days after the filing of the decision
2026 NY Slip Op 51299[U], at the official text
failed to demonstrate good cause for the delay
2026 NY Slip Op 51299[U], at the official text
rendered substantial justice between the parties
2026 NY Slip Op 51299[U], at the official text
| Court | Appellate Term, Second Department |
|---|---|
| Decided | June 12, 2026 |
| Citation | 2026 NY Slip Op 51299[U] |
| Area of law | Civil Procedure |
| Week | Week ending June 13, 2026 |
| Official text | Official decision: 2026 NY Slip Op 51299[U] |
| 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 | 271 |
Recommended citation
ESQ HQ, New York Law Watch, Cooper v Apostolic Gospel Church of Christ, Inc., 2026 NY Slip Op 51299[U] (Appellate Term, Second Department, June 12, 2026), https://esqhq.com/decisions/2026-ny-slip-op-51299-u/
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