On October 19, 2023, the First Department issued a decision in Magna Equities II, LLC v. Writ Media Group Inc., 2023 NY Slip Op. 05320, holding that a judgment must conform to the underlying decision, explaining:
A written order [or judgment] must conform strictly to the court’s decision, and in the event of an inconsistency between a judgment and a decision or order upon which it is based, the decision or order controls. A court exceeds its authority when it sua sponte vacates its prior order, as it has no revisory or appellate jurisdiction, sua sponte, to vacate its own order. Here, the court exceeded its authority in entering the judgment, which effectively reversed or vacated its prior confirmation order without notice. Accordingly, the court is directed to enter a revised judgment that conforms to the confirmation order with respect to damages and liability.
(Internal quotations and citations omitted).