219 East 7th Street Housing Development Fund Corp. v. 324 East 8th Street Housing Development Fund Corp.
The appellate court reversed a May 22, 2006, order from the Supreme Court, New York County, which had denied the plaintiff's motion to vacate a prior dismissal of the complaint. The appellate court deemed the plaintiff's motion as seeking renewal of the dismissal order under CPLR 2221 (e). Upon review of new evidence, including psychiatric affirmations, it was found that the plaintiff's former attorney failed to comply with a discovery deadline due to a diagnosed mental illness. Given that all required disclosure has since been provided and no prejudice to the defendants was shown, the court concluded that dismissal was an overly harsh penalty for nonvolitional failures related to the attorney's mental health. Consequently, the prior dismissal order was vacated, and the complaint was reinstated.