Chauhan v. AS Helios LLC

Summary

The Appellate Division, First Department affirmed dismissal of the plaintiffs’ claims against M&T Bank. It held that res judicata barred the claims because they arose from the same transaction and could have been litigated in a prior RPAPL article 15 quiet-title action, and the plaintiffs had a full and fair opportunity to litigate.

Holdings

1. Plaintiffs' claims were barred by res judicata because they arose from the same transaction between identical parties and could have been raised in the prior quiet-title action.
2. Plaintiffs' tactical decision not to oppose the prior motion did not alter the res judicata analysis because they had a full and fair opportunity to litigate.

Questions Presented

1. Whether plaintiffs' claims were barred by res judicata because they arose from the same transaction as the prior quiet-title action, involved identical parties, and could have been raised previously.
2. Whether plaintiffs' decision not to oppose M&T Bank's prior motion to quiet title deprived them of a full and fair opportunity to litigate.

Disposition

affirmed