Thomas A. Gleason v. John Jandrucko, Richard Spota, and Village of North Tarrytown

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting that “fraud involving injury to a single litigant” generally will not meet the level of fraud on the court
• holding that “neither perjury nor nondisclosure, by itself, amounts to anything more than fraud involving injury to a single litigant” and explaining that “credibility and veracity of a witness at issue in an original proceeding cannot be later challenged by way of an independent action”
• noting later discovered nondisclosure and perjury are not sufficient to state a claim as they only harm an individual litigant
• distinguishing the circumstances of the case from those in which fraud had prevented a creditor from proceeding against the garnishee of the debtor's assets in the first place based on the garnishee’s false representation
• “After-discovered evidence of alleged perjury by a witness is simply not sufficient for a finding of ‘fraud upon the court.’”
• “[A]llegations of nondisclosure during pretrial discovery do not constitute grounds for an independent action . . . .”

Source: CourtListener parenthetical corpus (CC0).