## Facts

- J. A. Mennella Foods Corporation (Mennella) (plaintiff) sued Neptune’s Nuggets, Inc. (Neptune) and Matlaw’s Food Products, Inc. (Matlaw) (collectively, defendants) in the County Court, Suffolk County.
- Mennella’s complaint pleaded two causes of action and sought money damages.
- The Suffolk County clerk entered a default judgment for Mennella in the amount of $11,836.82 after defendants failed to appear or answer.
- Neptune and Matlaw moved to vacate the default judgment and to dismiss the complaint, arguing the county court lacked personal jurisdiction because defendants were not doing business in Suffolk County when the action was commenced.
- Defendants also argued the default judgment was void because it exceeded the county court’s then-applicable $10,000 monetary jurisdictional limit.
- Mennella opposed the motion, contending (1) personal jurisdiction existed under New York’s long-arm statute, CPLR § 302, and (2) the county court could enter judgment up to $20,000 because the complaint asserted two causes of action (which Mennella characterized as permitting up to $10,000 per claim).

## Issues

1. Whether the County Court, Suffolk County had personal jurisdiction over Neptune and Matlaw based on Mennella’s reliance on CPLR § 302.
2. Whether the county court’s monetary jurisdiction permitted entry of a single default judgment for $11,836.82 when the complaint asserted two causes of action and the stated jurisdictional limit was $10,000.
3. Whether a clerk-entered default judgment must be vacated when the court lacked jurisdiction to enter the judgment as docketed.

## Decision

- The court addressed defendants’ jurisdiction-based attack on the clerk-entered default judgment.
- The court determined that the validity of the default judgment turned on jurisdictional limits applicable to the county court and the amount for which judgment was entered.
- The court vacated the default judgment and granted relief based on the jurisdictional defect raised by defendants’ motion.

## Legal Principles

- A default judgment is subject to vacatur if the court lacked jurisdiction to enter the judgment.
- A court of limited monetary jurisdiction cannot enter a money judgment that exceeds its statutory jurisdictional ceiling.
- Pleading multiple causes of action does not necessarily expand a limited-jurisdiction court’s authority to enter a single money judgment beyond the court’s statutory maximum.
- Personal jurisdiction over a non-domiciliary under CPLR § 302 requires a statutory basis tied to the defendant’s in-state conduct and a connection between that conduct and the claims asserted.

## Conclusion

In J.A. Mennella Foods Corp. v. Neptune’s Nuggets, Inc., the Suffolk County County Court considered defendants’ motion to set aside a clerk-entered default judgment and dismiss for jurisdictional defects. Defendants challenged both personal jurisdiction and the court’s authority to enter a money judgment above the county court’s jurisdictional limit. The court granted jurisdiction-based relief by vacating the default judgment entered for $11,836.82.


J.A. Mennella Foods Corp. v. Neptune's Nuggets, Inc., 74 Misc. 2d 839, 346 N.Y.S.2d 43 (1973)