SUBSTITUTED SERVICE UNDER CPLR 308(2)
IN CIVIL ACTIONS AND UNDER RPAPL 735(1) IN SUMMARY PROCEEDINGS: A COMPARATIVE
ANALYSIS, WITH SOME OBSERVATIONS ON SERVICE UNDER FAMILY COURT ACT SECTION
427(a)
By David
Calender, Esq., Attorney at Law
Founder
and Chief Executive Officer, New York Case -Winning Strategies, LLC
The New York civil practitioner is,
presumably, thoroughly conversant with the hornbook rule that, in order for a
court to exercise personal jurisdiction over a defendant in a civil action (in
summary Landlord-Tenant proceedings, a “respondent”), the defendant must be properly
served with process (in the typical civil case, a Summons; in Family Court
proceedings, a Summons and Petition; in Summary landlord-tenant proceedings, a Notice
of Petition and Petition).
Service of process by substituted
service, specifically the method commonly referred to as “deliver-and-mail”
service, is authorized by subdivision (2) of Section 308 of the Civil Practice
Law and Rules (“CPLR 308(2)”) in a civil case and by Section 735(1) of the Real
Property Actions and Proceedings Law (“RPAPL 735(1)”) in Summary proceedings.
However, these statutory provisions
must be understood and utilized with a clear understanding that, notwithstanding
the appearance at first blush that they contain identical, interchangeable
provisions, there is a subtle but crucial distinction between the two: the method
provided by RPAPL Section 735(1) for deliver-and-mail substituted
service is narrower in the scope of its application and, consequently, presents
a pitfall for the unwary petitioner in a Summary proceeding, whereas service
pursuant to CPLR 308(2) under similar circumstances is routinely sustained by
the courts as valid. For the reasons discussed below, the practitioner in
Landlord-Tenant proceedings is advised to proceed with caution when effecting deliver-and-mail
service upon a tenant pursuant to RPAPL 735(1).
Failure by the litigant in summary landlord-tenant
proceedings to appreciate the practical distinction between these two
provisions has resulted in dismissal of many a Summary proceeding on personal
jurisdictional grounds -- often after much time, effort and expense have been
invested in procuring a Judgment of Possession and/or Money Judgment for rent
owed, thus forcing the anguished petitioner landlord to resort to recommencing
the proceeding ab initio. It
is hoped that the reader will benefit from this article’s comparative analysis
of some notable cases that illustrate the difference in application in the real
world of these discrete categories of deliver-and-mail substituted service.
Where the defendant in a civil action
is an individual (a “natural person”), Section 308 of the CPLR provides that personal
service may be made by delivering the legal process: (i) directly to the
defendant (CPLR 308(1)); (ii) to someone of suitable age and discretion at the
defendant’s “actual place of business, dwelling place or usual place of abode”
and mailing a copy of the summons to the defendant’s last known residence or
actual place of business” (CPLR 308(2)); (iii) to an agent designated under
CPLR 318 (CPLR 308(3)); and (iv) where, notwithstanding diligent, but
unsuccessful, efforts to effect service pursuant to CPLR 308(1) and CPLR
308(2), by affixing the process to the door of the defendant’s “actual place of
business, dwelling place or usual place of abode within the state” And mailing
a copy of the summons to the defendant at his/her actual place of business or
last known residence (CPLR 308(4)).
Scope and Operation of CPLR 308(2) in
Civil Actions Generally (Except Divorce)
The provisions of CPLR 308(2),
implicated in this article, provides for the following method of
deliver-and-mail substituted service:
Section 308. Personal service upon a natural person
Personal service upon a natural person shall be made
by any of the following methods: . . .
2. by
delivering the summons within the state to a person of suitable age and
discretion at the actual place of business, dwelling place or usual place of
abode of the person to be served and by either mailing the summons to the
person to be served at his or her last known residence or by mailing the
summons by first class mail to the person to be served at his or her actual
place of business in an envelope bearing the legend “personal and confidential”
and not indicating on the outside thereof, by return address or otherwise, that
the communication is from an attorney or concerns and action against the person
to be served, such delivery and mailing to be effected within twenty days of
each other; proof of such service Shall be filed with the clerk of the court
designated in the summons within twenty days of either such delivery or
mailing, whichever is effected later; service shall be complete ten days after
such filing; proof of service shall identify such person of suitable age and
discretion and state the date, time and place of service . . .
Thus, pursuant to CPLR 308(2), the
process to be served need only be delivered to “a person of suitable age and
discretion at the actual place of business, dwelling place or usual place of
abode of the person to be served” See, e.g., Bank of New York
v. Espejo, 92 A.D.3d 707, 708 (2nd Dept. 2012) (holding that
“[valid] service pursuant to CPLR 308(2) may be made by delivery of the summons
and complaint to a person of suitable age and discretion who answers the door
at the defendant’s residence, but is not [necessarily] a resident of the
subject property”).
In Espejo, an action to
foreclosure a mortgage, the defendants were served pursuant to CPLR 308(2) with
copies of the summons and complaint at their home by delivery of a copy of the
summons and complaint to one Michael Guzman, referred to in the affidavit of
service as a cotenant, and by mailing two additional copies of the summons and
complaint to the defendants at the same address. The defendants did not respond
to the summons and complaint and a default judgment of foreclosure and sale was
entered against them. Some eight months later, the defendants moved to vacate
the judgment entered upon their default. Insofar as relevant to this article,
in support of the motion challenging the validity of service, one defendant
submitted an affidavit stating that she was not validly served with a copy of
the summons and complaint because Michael Guzman, who received service, did not
reside at the property where service was effected. The Supreme Court, Kings
County, denied her motion to invalidate service on this ground and an appeal
ensued.
On appeal, the Appellate Division,
Second Department, affirmed the denial of the motion challenging the validity
of service, holding that, notwithstanding the defendant’s sworn statement that
Michael Guzman did not reside at the property where the process was served,
[v]alid service pursuant to CPLR 308(2)
may be made by delivery of the summons and complaint to a person of suitable
age and discretion who answers at the door at a defendant’s residence, but is
not a resident of the property.
In support of this conclusion, the
Appellate Division, Second Department, cited a pair of its previous decisions,
one in the context of an action to recover a real estate broker’s commission (U.S.
1 Brookville Real Estate Corp. v. Spallone, 21 A.D.3d 480. 481-482 (2005))
and the other in the context of an action to recover damages for personal
injuries (Chesman v. Lippoth, 271 A.D.2d 567 (2000)).
Thus,
the law in New York is by now well-settled that, under CPLR 308(2), assuming
that the prescribed follow-up mailing and filing with the court is completed, the
requirement of deliver-and-mail substituted service is satisfied merely by
delivering the summons to any individual of suitable age and discretion who
answers the door at the defendant’s residence (described by the statute as
defendant’s “dwelling place or usual place of abode”), even if such person is
not a resident of the premises. For this reason, the trial court and the Appellate
Division rejected the argument by the defendant in Espejo, supra,
that service was invalid because Michael Guzman did not reside at the home
where he answered the door and took delivery of the Summons.
That said, an important procedural
question arises: What if the facts are identical, except that the legal
document handed to the person who answers the door is not a Summons (in
a mortgage foreclosure or breach of contract or personal injury action), but
rather a Notice of Petition in a Summary Proceeding to recover
possession of real property and/or to recover rent arrears? Would the analysis in the three cited
decisions of the Appellate Division, Second Department, apply to invalidate
service of process under the same circumstances in a Summary proceeding?
(Parenthetically, appeals lie from the Landlord-Tenant Court to the Appellate
Term of the Supreme Court, comprising a panel of sitting Justices of the
Supreme Court, not the Appellate Division.)
Scope and Operation of RPAPL Section
735(1) in Summary Proceedings
Generally, there are two types of
summary proceedings: (1) non-payment proceedings and (2) holdover proceedings.
A discussion of the requisite elements of each, including the contents of
predicate notices, is beyond the scope of this article, which focuses on the
service methods necessary to validly initiate legal proceedings and, relatedly,
whether personal jurisdiction is acquired in certain situations. Suffice it to
say that the rules governing service of process are the same in both
non-payment and holdover proceedings. In both cases, the “process” that is
required to be served in order to confer jurisdiction over the tenant
(“respondent”) is a Notice of Petition and Petition.
However, it should be noted that, in
New York City, before the filing of those documents, Section 232-a of the Real
Property Law (RPL) requires that a written predicate notice (“Notice
Terminating Tenancy” or “Notice to Quit”) be served on the tenant “in the same
manner as the Notice of Petition and Petition,” notwithstanding that a Notice
to Quit is technically not “process” as defined by statute. Accordingly, the
rules described below for service of a Notice of Petition and Petition in
Summary proceedings apply with equal force to service of a predicate Notice to
Quit/Notice Terminating Tenancy: failure to serve it in the same manner as the
Notice of Petition and Petition will result in dismissal of the proceeding.
Whereas CPLR 308(2) prescribes the
method for deliver-and-mail substituted service upon an individual defendant in
a civil action, the rules governing that category of substituted service in
Summary proceedings are set forth in Section 735(1) of the Real Property
Actions and Proceedings Law. There are essentially three authorized methods to
serve the Notice of Petition and Petition: (1) personal delivery upon the
respondent tenant; (2) substituted service a/k/a deliver-and-mail service; or
(3) conspicuous place service, otherwise called “nail-and-mail” or
“affix-and-mail” service. It should be borne in mind that the third category,
i.e., conspicuous place service a/k/a nail-and-mail or affix-and-mail service,
is also a method of substituted service.
However, that service method will be discussed in a later article and we
are here concerned only with the second referenced method, deliver-and-mail.
The deliver-and-mail method of substituted
service is authorized by Section 735(1) of the RPAPL as follows:
Section 735. Manner of service; filing; when service
complete
1.
Service of the
notice of petition and petition shall be made by personally delivering them to
the respondent; or by delivering to and leaving personally with a person of
suitable age and discretion who resides or is employed at the property sought
to be recovered, a copy of the notice of petition and petition, if upon
reasonable application admittance can be obtained and such person found who
will receive it; . . . [followed by mailing copies to respondent within one
day by registered or certified mail and by regular first class mail and filing
proof of service with the court within three days after]. (italics added)
Careful perusal of the foregoing
statutory language reveals four significant features. First, the delivery component
of the deliver-and-mail procedure must take place, not at the respondent’s
actual place of business, dwelling place or usual place of abode as is the case
with CPLR 308(2) service, but “at the property sought to be recovered.”
Second, should the process server learn
that the individual who answers the door is not the respondent him/herself and
thus resort to the deliver-and-mail method, the server must ascertain that the
individual who accepts delivery of the papers actually “resides or is employed”
at the premises. There is no such requirement in CPLR 308(2); the person who
takes delivery need only be “at” the premises at the time of accepting delivery
of the papers.
Third,
the follow-up mailing required by RPAPL 735(1) must be by registered or
certified mail and by regular first-class mail, whereas the mailing
provision in cases under CPLR 308(2) require only regular first-class mailing.
Fourth, under RPAPL 735(1), proof of
mailing must be filed with the court “within three days after the mailing” (service
is deemed complete upon filing, per RPAPL 735(2)(b)); whereas, under CPLR
308(2), twenty days is provided for the filing of proof of mailing, and service
is deemed complete ten days after such filing.
A
recent decision, dated May 17, 2023, that illustrates the court’s application
of the “resides or is employed” requirement of RPAPL 735(1) – with disastrous
results for the landlord and its process server – is the case of Wilmington Trust, N.A. v.
Walcott, et al. (NYSCEF Index #L&T 301234/20), a decision of the Civil
Court, Queens County, Housing Part. In Walcott, a post-foreclosure
holdover proceeding, the court conducted a traverse hearing on March 30, 2023 to
determine whether the tenant was properly served with process (in this case a
Notice to Quit) by the deliver-and-mail method pursuant to RPAPL Section 735(1).
(Trial attorneys
interested in mastering this aspect of civil litigation may obtain sample
Traverse Hearing transcripts at www.newyorkcasewinningstrategies.com.)
The process server, who had 25 years
of experience, testified that he delivered the papers to a young black male,
who did not identify himself, and thereafter mailed a set of the papers
addressed to the tenant at the premises sought to be recovered. The tenant, a
73-year-old man, testified that he resided at the subject premises with his
wife and that no other male resided at the premises. He denied ever receiving
the Notice to Quit. Asked about the young black male described in the process
server’s Affidavit of Service and about whom the server testified, the tenant
stated that no one resided at the premises besides his wife and himself.
The court, crediting the testimony of
the tenant, held that service of the Notice to Quit was invalid and dismissed
the proceeding without prejudice. The court concluded that dismissal was
warranted because the process server failed to offer any testimony that the
young black male whom he purportedly served actually resided at the subject
premises at the time of the service.
The
newly-minted Walcott decision should be seen by the New York
practitioner and process server in landlord-tenant cases as a cautionary tale:
all deliver-and-mail service is not created equal. While the validity of CPLR
308(2) service in other civil actions simply requires that the suitable age/discretion
person be “at” the premises when the papers are delivered, if the very same method
of service is utilized in L&T proceedings, counsel for the landlord facing
a challenge to personal jurisdiction must be prepared to prove by a
preponderance of the credible evidence that the person served actually resided or
was employed at the subject premises at the time of the service. Failure to
carry that evidentiary burden at a traverse hearing will result in dismissal of
the proceedings on jurisdictional grounds, albeit without prejudice.
An
appreciation of the subtle distinction, discussed in this article, between CPLR
308(2) substituted service and its parallel provision in RPAPL 735(1) is
particularly important for the New York attorney and process server on both
sides of the litigation divide in Landlord-Tenant proceedings in 2023, where
the number of people who are due to lose their homes in post-foreclosure
eviction proceedings is on the rise.
Now that the pandemic’s renter protection programs have expired, eviction
filing rates are soaring. According to real estate statistics compiled by ATTOM
Data, nearly 100,000 foreclosure actions have been filed nationwide through
March 31, 2023 – the twenty-third consecutive month, with the rate
accelerating. Nationwide, lenders started the foreclosure process on 21,770
U.S. properties in January 2024, up 6 percent from December 2023 and up 5
percent from a year ago (January 2023).
New York State is among the states
with the most foreclosure filings, ranking in the top 5 states (1,341
foreclosure starts in January 2024). In New York City, the “Big Apple” recorded
the highest number of lenders of all U.S. cities who started the foreclosure
process in January 2024.
As for renters, New Yorkers are
faring no better than homeowners. In 40 of the State’s 62 counties, the
eviction filings for renters were higher in 2022 than before the pandemic; in
two counties, filings to evict tenants more than doubled when compared to 2019.
Attorneys representing litigants in
foreclosure actions in New York State Supreme Court as well as in
post-foreclosure eviction proceedings would do well to remember the process
service rules discussed in this article.
Deliver-and-Mail Substituted Service
in Family Court Proceedings (FCA Section 427)
Is the deliver-and-mail method of substituted
service available in Family Court proceedings? If so, on what side of the
procedural divide does such service fall, i.e., must the suitable age person
who answers the door actually “reside” or be “employed” at the premises in
order for service to be valid, as is the case in Summary Landlord-Tenant
proceedings (RPAPL 735(1)), or, is service proper by a simple showing that the
suitable age person who accepted the papers was merely “at” the residence/actual
place of business of the person to be served, as permitted by CPLR 308(2)?
The answer is to be found In Section
427(1) of the New York Family Court Act. By way of background, the Family Court
is a creature of the New York Family Court Act (“FCA”), which vests in that
court exclusive original subject-matter jurisdiction over a myriad of domestic
relations proceedings. It should be noted, however, that although most
subject-matter jurisdictional grants are specified in the FCA, the subject
areas enumerated in that statute are not exhaustive; others are set forth in
the Social Services Law, the Domestic Relations Law, the State Constitution,
and the Unconsolidated Laws.
Section 115 of the FCA describes the cases
in which the Family Court exercises exclusive subject-matter jurisdiction. They
include, but are not limited to, the following: support (child and spousal); custody
and adoption of children; paternity determinations and support of
out-of-wedlock children; abuse and neglect determinations; family offense cases
(concurrent and simultaneous with Criminal Court); permanent termination of
parental rights; and adjudication of juvenile delinquency status.
With respect to service of process in
general and deliver-and-mail substituted service in particular, this article
will focus on service of process in what is by far the most common proceeding
in New York Family Court: child support cases.
The Family Court’s original
jurisdiction over child support proceedings is derived from Article 4 of the
Family Court Act. Child support proceedings are commenced by the filing of a child
support Petition under Section 426 of the statute. The same Section provides
that, upon the filing of the Petition, the court “may cause” a Summons to be
issued (it invariably does).
Pursuant to Section 427(a) of the FCA,
the Summons, which includes a return date at which the respondent is to
initially appear, is to be served with the Petition in the following manner:
Section 427. Service of summons
(a) Personal
service of a summons and petition may be made by delivery of a true copy
thereof to the person summoned at least eight days before the time stated
therein for appearance; or by delivery of a true copy thereof to a person of
suitable age and discretion at the actual place of business, dwelling place or
usual place of abode of the person to be served and by mailing a true copy
thereof to the person to be served at his last known residence at least eight
days before the time stated in the summons for appearance; proof of service
shall identify such person of suitable age and discretion and state the date,
time and place of service.
(b) If after a
reasonable effort, personal service is not made, the court may at any stage in
the proceedings make an order providing for substituted service in the manner
provided for substituted service in the civil practice law and rules [CPLR
308].
As to subdivision (a), the term “personal service,” as used therein,
mirrors the service methods of subdivisions (1) and (2) of CPLR 308 in that it
encompasses both in-hand delivery to the respondent as well as deliver-and-mail
service to a person of suitable age and discretion at the respondent’s actual
place of business, dwelling place or usual place of abode, followed by a
mailing to respondent at his or her last known residence. The mailing
provision, however, differs from CPLR 308(2) in that, since the Family Court
Summons and Petition includes a return date at which the respondent is to
initially appear, the mailing must be done at least eight days before the
appearance date stated on the Summons. Notably, although proof of such mailing
would undoubtedly be required in the courtroom on the return date, there is no
requirement that proof of mailing be filed with the court, as is the case with
CPLR 308(2) deliver-and-mail service.
Regarding “affix-and-mail” service,
also referred to as “nail-and-mail” service, none of the three subdivisions of FCA
Section 427 contains any provision for such service, evidently for privacy
reasons (compare CPLR 308(4)). Instead, subdivision (b) of FCA Section 427 expressly
incorporates by reference the “court-ordered service” mechanism contained in
subdivision (5) of CPLR 308 in the event that due diligence efforts at in-hand
service and deliver-and-mail service prove futile “after a reasonable effort.”
The highly peculiar subdivision (c)
of FCA Section 427, which provides for service “by mail alone” and which is
authorized “whether or not service is attempted under subdivision (a) or (b) of
this section [427],” is beyond the scope of this article and will be discussed
in a separate article discussing substituted service methods other than
deliver-and-mail service.
As long ago as 1950, the United States Supreme
Court famously stated that, in order to pass constitutional muster, the method
of service utilized must be “reasonably calculated, under all the
circumstances, to apprise interested parties of the pendency of the action” (Mullane
v. Central Hanover Trust Co., 339 U.S. 306, at 314). The discussion in this
article clearly demonstrates that the overriding legislative intent of the
deliver-and-mail provisions of CPLR 308(2), RPAPL 735(1) and FCA 427 is to safeguard
the due process right of a defendant or respondent under the Constitutions of
the United States and New York to be given adequate notice of legal proceedings
initiated against him or her in order to have a reasonable opportunity to
contest such proceedings.
Nonetheless, for the New York trial
attorney and process server, the essential takeaway from this article is that,
in Summary landlord-tenant proceedings, all methods of deliver-and-mail substituted
service are not created equal. We have seen that in cases where
deliver-and-mail service under the CPLR and Family Court Act are routinely
sustained, the courts in summary landlord-tenant proceedings will, pursuant to
RPAPL 735, invalidate the same service method and dismiss the proceeding for
lack of personal jurisdiction absent proof that the person of suitable age and
discretion to whom the papers are delivered actually resides or is employed at
the premises where the service is effected.
#personaljurisdiction
#serviceofprocess
#substituted service
#cplr308
#rpapl735
#fca427
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