determination of any claim in New York

2021RPAPL 1501(1) contains broad standing rules authorizing a person who "claims an estate or interest in real property" to "maintain any action against any other person . . . to compel the determination of any claim adverse to that of the plaintiff." The statute is not subject to the same standing principles that are applicable to contract law ( see Wellington v Financial Freedom Acquisition LLC , 132 AD3d 506, 507 [1st Dept 2015] ["Defendant's reliance on the principle of contract law that a person who was not a party to the contract or a third-party beneficiary thereof cannot assert a claim for

2019RPAPL 1501(1) provides that a person who "claims an estate or interest in real property . . . may maintain an action against any other person . . . to compel the determination of any claim adverse to that of the plaintiff which the defendant makes, or which it appears from the public records, or from the allegations of the complaint, the defendant might make" ( see Wellington v Financial Freedom Acquisition LLC , 132 AD3d 506, 506-507 ).

2017Group, Inc. v Stephens, 91 AD3d 801 [2012]).

2017Group, Inc. v Stephens, 91 AD3d 801, 803 [2012]; First Natl.

2025Fund Socy., FSB , 219 AD3d 798, 799 [2d Dept 2023]), the 2013 foreclosure action could not be considered terminated for purposes of RPAPL 1501(4) until January 14, 2021, when this Court dismissed the action on procedural grounds ( MTGLQ Invs., L.P. v Shay , 190 AD3d 527 , 528 [1st Dept 2021], lv denied 37 NY3d 908 [2021]).

2025For example, in Elam v Altered Ego Realty Holding Corp. , 114 AD3d 901, 904 [2d Dept 2014], the Court denied a default judgment because the defaulting predecessor "claimed no interest in the subject premises" and therefore, was not a proper party in an action to quiet title.

2025For example, in Elam v Altered Ego Realty Holding Corp. , 114 AD3d 901, 904 [2d Dept 2014], the Court denied a default judgment because the defaulting predecessor "claimed no interest in the subject premises" and therefore, was not a proper party in an action to quiet title.

2017RPAPL 1501 provides that any person who “ ‘claims an estate or interest in real property’ may ‘maintain an action against any other person ... to compel the determination of any claim adverse to that of the plaintiff which the defendant makes, or which it appears from the public records, . . . the defendant might make’ ” (Deramo v Laffey, 149 AD3d 800, 802 [2017], quoting RPAPL 1501 [1]; see Wellington v Financial Freedom Acquisition LLC, 132 AD3d 506, 506-507 [2015]; ABN AMRO Mtge.

2017RPAPL 1501 (1) provides that any person who “claims an estate or interest in real property” may “maintain an action against any other person ... to compel the determination of any claim adverse to that of the plaintiff which the defendant makes, or which it appears from the public records, . . . the defendant might make.” A deed based on forgery or obtained by false pretenses is void ab initio, and a mortgage based on such a deed is likewise invalid (see Matter of Marini, 119 AD3d 584, 585 [2014]; Jiles v Archer, 116 AD3d 664, 666 [2014]; ABN AMRO Mtge.

2017RPAPL 1501 (1) provides that any person who “claims an estate or interest in real property” may “maintain an action against any other person ... to compel the determination of any claim adverse to that of the plaintiff which the defendant makes, or which it appears from the public records, . . . the defendant might make.” A deed based on forgery or obtained by false pretenses is void ab initio, and a mortgage based on such a deed is likewise invalid (see Matter of Marini, 119 AD3d 584, 585 [2014]; Jiles v Archer, 116 AD3d 664, 666 [2014]; ABN AMRO Mtge.