On December 17, 2025, the Second Department issued a decision in Normandy Capital Trust v. 223 15th St, LLC, 2025 NY Slip Op. 07011, holding that an LLC member lacked standing to challenge a foreclosure on the LLC’s property, explaining:
A membership interest in a limited liability company is personal property, and therefore, a member has no interest in specific property of the limited liability company.
Here, as an alleged member of the borrower, 223 Sam lacked standing to seek cancellation of the note or mortgage executed by the borrower. In other words, 223 Sam failed to demonstrate that it had a real and substantial interest in the outcome of this action. Accordingly, under the circumstances, the Supreme Court properly denied that branch of 223 Sam’s motion which was for leave to intervene in the action.
(Internal quotations and citations omitted).