A New York appellate court has issued a ruling that affects Unity Funeral Chapels, Inc. The court modified a previous decision that awarded $2.5 million in damages to plaintiffs in a negligence case. This ruling allows for a new hearing to determine damages against Unity, which failed to respond to the original lawsuit.
The case, Williams v. New York City Office of Chief Medical Examiner, was decided by the Appellate Division of the Supreme Court of the State of New York on June 24, 2026. The court's decision comes after Unity Funeral Chapels appealed a lower court's order that had granted a default judgment against it. The ruling is significant as it highlights the legal standards surrounding default judgments and the assessment of damages in negligence cases.
Background
The plaintiffs in this case, Tonya Williams and others, filed a lawsuit against Unity Funeral Chapels and other defendants, claiming negligence, breach of contract, and fraud. Unity Funeral Chapels did not respond to the lawsuit, leading the plaintiffs to file an unopposed motion for a default judgment. In July 2021, the lower court granted this motion, allowing the plaintiffs to proceed without Unity's participation.
Following this, an inquest was held in October 2021, where the court determined that each plaintiff was entitled to $750,000 in general damages and $500,000 in punitive damages. The total judgment against Unity was set at $2.5 million. After this judgment, Unity sought to have the court vacate the default judgment and the damages awarded, claiming it had not been properly served with the lawsuit.
The Ruling
The appellate court, led by Justice Angela G. Iannacci and joined by Justices Linda Christopher, Barry E. Warhit, and Carl J. Landicino, ruled on the appeal from Unity Funeral Chapels. The court found that Unity was not entitled to vacate the default judgment based on a lack of jurisdiction. The court stated, "The court does not have personal jurisdiction over a defendant when a plaintiff fails to properly effectuate service of process." However, the court also acknowledged that Unity's submissions did not sufficiently defeat the presumption of proper service created by the affidavit of the plaintiff's process server.
Despite this, the court exercised its discretion to grant Unity's request to vacate the judgment. The court noted that the damages awarded were excessive and unwarranted, stating, "An unwarranted and excessive award after inquest will not be sustained." The court ordered a new inquest to determine damages, to be conducted by a different justice.
Impact
This ruling has significant implications for Unity Funeral Chapels and the plaintiffs. By allowing a new hearing on damages, the court has opened the door for a reassessment of the financial penalties imposed on Unity. The decision emphasizes the importance of proper service in legal proceedings and the potential for courts to modify excessive damage awards.
The ruling also serves as a reminder to defendants in similar situations about their rights and the procedures available to contest default judgments. It illustrates that even when a defendant fails to respond, courts can still exercise discretion in reviewing the fairness of damage awards.
What's Next
Unity Funeral Chapels can prepare for the upcoming new inquest to determine damages. The court has remitted the case to the Supreme Court, Kings County, for this purpose. There are no indications in the court filing about whether the plaintiffs plan to appeal this decision or if there are related cases pending.