Carrington Mtge. Servs., LLC v. Sudano
In this mortgage foreclosure action, the plaintiff, Carrington Mortgage Services, LLC, appealed an order from the Supreme Court, Erie County, which dismissed its action against Linda M. Sudano on the grounds of lack of standing. The Appellate Division, Fourth Department, affirmed the dismissal, rejecting the plaintiff's arguments that collateral estoppel barred reexamination of standing and that the court erred in its determination. The appellate court emphasized that every court retains continuing jurisdiction to reconsider its interlocutory orders. Crucially, the plaintiff failed to include the necessary documents, such as the summons and complaint and evidence of assignment, in the record on appeal, preventing the court from verifying its standing as the holder or assignee of the note and mortgage at the commencement of the action. The court concluded that the plaintiff's failure to assemble a proper record compelled the affirmation of the lower court's order.