Kathryn A. Miller and David C. Miller v. Naithani
Kathryn A. Miller and David C. Miller, as co-executors of the Estate of Lewis A. Miller, deceased et al. v. Mahesh Naithani
- Aaron
- 1:25-cv-08384
- U.S. District Court · Southern District of New York
- 5
In Miller v. Naithani, Judge Aaron ordered plaintiffs to address personal jurisdiction before deciding their default-judgment motion.
The plaintiffs, as co-executors of the Estate of Lewis A. Miller, and defendant Mahesh Naithani are affected; the court required the plaintiffs to provide further information before ruling on their default-judgment motion.
What happened
In Miller v. Naithani, the plaintiffs—co-executors of the Estate of Lewis A. Miller—seek payment on a promissory note from Mahesh Naithani. The opinion states that Naithani is a California citizen and that the Estate is New York-based.
Before considering the plaintiffs’ request for a judgment because Naithani did not appear, the court examined whether New York courts have power over him. The court expressed serious doubts about both New York’s law and constitutional requirements for personal jurisdiction.
Judge Aaron ordered the plaintiffs to file a supplemental memorandum by September 8, 2026, addressing personal jurisdiction and to serve it on Naithani by email. The order did not decide the default-judgment motion.
The detailed version
- Kathryn A. Miller and David C. Miller v. Naithani · No. 1:25-cv-08384
- Aaron
- Aug. 22, 2026
Background
Kathryn A. Miller and David C. Miller, acting as co-executors of the Estate of Lewis A. Miller, sued Mahesh Naithani to collect on a promissory note. The opinion describes the Estate as New York-based and Naithani as a citizen of California. The plaintiffs moved for a default judgment under Rule 55 of the Federal Rules of Civil Procedure, which allows a court to enter judgment when a defendant fails to appear and defend.
Personal Jurisdiction
Before granting a default judgment, the court may ensure that it has personal jurisdiction—the legal authority to exercise power over the defendant. In this diversity case, the court explained that it must determine both whether New York law permits jurisdiction and whether exercising jurisdiction would satisfy constitutional due-process requirements.
The court focused on New York’s law allowing jurisdiction over a non-New York defendant who transacts business in New York when the claim arises from that business. The court stated that this requires purposeful use of New York’s benefits, such as contracting or performing in New York or deliberately creating a business relationship there. The court also discussed general jurisdiction, which generally applies when an individual is essentially at home in the state, and specific jurisdiction, which depends on the defendant’s contacts with the state and whether jurisdiction would be reasonable.
Order
The court stated that it had serious doubts about whether personal jurisdiction existed under New York law and whether exercising jurisdiction would comply with due process. It ordered the plaintiffs to file a supplemental memorandum no later than September 8, 2026, addressing personal jurisdiction under New York law and the U.S. Constitution. The plaintiffs must serve the memorandum on Naithani by email and file proof of service on the electronic docket.
The order did not grant or deny the plaintiffs’ motion for default judgment and did not decide the merits of their claim on the promissory note.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.