Castelli v. Castelli, 63 N.Y.2d 424 (1984)

A party who is not aggrieved by a judgment lacks standing to appeal that judgment.

Summary

In a matrimonial dispute, the wife appealed a grant of reverse summary judgment in favor of the husband. The New York Court of Appeals held that the wife lacked standing to appeal because she was not aggrieved by the grant of reverse summary judgment to the husband. The court reasoned that the wife only had standing to appeal issues where the judgment caused her legal grievance. The Court of Appeals reversed the Appellate Division’s order and remitted the case with instructions to dismiss the wife’s appeal and consider any unresolved issues from the husband’s appeal, without prejudice to the wife seeking reconsideration based on intervening legislation.

Facts

The case involved two separate actions between a husband and wife. The husband sought reverse summary judgment. Special Term granted the husband’s motion for reverse summary judgment and entered a judgment of divorce in his favor. The wife appealed this decision to the Appellate Division.

Procedural History

Special Term granted the husband’s motion for reverse summary judgment. The wife appealed to the Appellate Division. The Court of Appeals reversed the Appellate Division’s order, remitting the case with directions to dismiss the wife’s appeal and consider any unresolved issues from the husband’s appeal.

Issue(s)

Whether the Appellate Division had jurisdiction to entertain the wife’s appeal of the grant of reverse summary judgment to the husband, when the wife was not aggrieved by that judgment.

Holding

No, because the plaintiff wife was not aggrieved by the grant of reverse summary judgment to the husband. Thus, the Appellate Division lacked jurisdiction to hear her appeal.

Court’s Reasoning

The Court of Appeals held that the wife lacked standing to appeal the grant of reverse summary judgment because she was not aggrieved by it. Only a party who is legally harmed or negatively impacted by a court’s decision has the right to appeal that decision. The court stated the Appellate Division was without jurisdiction to entertain her appeal because she was not aggrieved by the summary judgment in favor of her husband.

The court emphasized that the right to appeal is predicated on being aggrieved by the order or judgment in question. Since the reverse summary judgment was in the husband’s favor, the wife could not claim to have been legally harmed by it. The court, however, allowed the wife to seek reconsideration based on intervening legislation that was enacted after the initial judgment.