On October 28, 2025, the First Department issued a decision in Astraea NYNY LLC v. Ganley, 2025 NY Slip Op. 05915, holding that a trial court was not required to hold a hearing on a contempt motion when the facts were not in dispute, explaining:
[D]efendant contends that the court was required to hold a hearing before issuing the December 2023 contempt order. The court was not required to hold a such a hearing because defendant’s opposition to the motion did not raise a factual dispute as to the elements of civil contempt, or the existence of a defense. Plaintiff submitted proof that it had offered to allow defendant to sell the vehicles in Ireland and remit the sales proceeds. In opposition, defendant merely stated, “I do not agree with [plaintiff] about the valuation, collectability, or the method of distributing” the vehicles. Defendant’s opposition does not establish that defendant was unable to comply with the October 2023 order.
(Internal quotations and citations omitted).