In Walker v. Reyes , when Marianne Walker sued Hector Reyes for a "wrongful death," the latter claimed the court lacked jurisdiction over him.
After Walker and Reyes were involved in an accident, Reyes gave officers a New York address which was on file with the Commissioner of Motor Vehicles (CMV).
When Walker later filed suit, and served Reyes as dictated by state law, Reyes claimed to have relocated to California and that he was no longer a New York resident.
Although he thought it hadn't been required, Reyes admitted he hadn't notified the CMV of his address change.
When the New York County Supreme Court denied his jurisdictional objection, Reyes appealed to the Appellate Division, Second Department, which affirmed the lower court's decision.
NY law requires those holding a drivers' license to notify the CMV of an address change within 10 days. Because Reyes failed to do so, he was prevented from challenging service of the pleadings at his New York address.
That outcome didn't serve Reyes.
To download a copy of the Appellate Division's decision, please use this link: Walker v. Reyes