The Flexibility of New York Surrogate’s Court Jurisdiction Under SCPA § 202

In estate litigation, procedural rules often seem rigid, but Surrogate’s Court Procedure Act (SCPA) § 202 offers a reminder that flexibility exists within the law. This rule clarifies that the jurisdiction of the Surrogate’s Court is not limited to the specific proceedings listed in the statute. Instead, the court retains broad authority to exercise its jurisdiction whenever necessary, even if a particular type of proceeding is not explicitly provided for.

§ 202. Enumerated proceedings not exclusive

The proceedings enumerated in this act shall not be deemed exclusive and the court is empowered in any proceeding, whether or not specifically provided for, to exercise any of the jurisdiction granted to it by this act or other provisions of law, notwithstanding that the jurisdiction sought to be exercised in the proceeding is or may be exercised in or incidental to a different proceeding.

What Does SCPA § 202 Mean?

At its core, SCPA § 202 states that:

• The enumerated proceedings in the SCPA are not exclusive. Just because a particular type of action is not listed in the statute does not mean the Surrogate’s Court lacks jurisdiction over it.
• The court can exercise its jurisdiction in any proceeding, regardless of whether that jurisdiction is typically invoked in another type of proceeding.
• Even if an issue could be addressed in the context of a different proceeding, the court is not restricted to handling it only in that specific procedural context.

Why This Matters

This rule is crucial because estate matters often involve complex and overlapping issues. If courts were limited to handling only the specific proceedings listed in the SCPA, it could create unnecessary procedural roadblocks. Instead, SCPA § 202 ensures that the Surrogate’s Court can adapt its jurisdiction to the needs of a case, allowing for more efficient and practical resolutions.

Practical Applications

Consider a situation where a dispute arises over an estate accounting, but resolving it requires addressing a contested trust issue. Under SCPA § 202, the court would not be constrained to addressing the trust matter solely within a formal trust proceeding—it could address the issue as part of the accounting dispute if doing so serves judicial efficiency.

Similarly, if a litigant attempts to challenge the validity of a document that impacts an estate but does so in a proceeding not explicitly designated for such challenges, the court can still exercise jurisdiction.

Conclusion

SCPA § 202 reinforces the broad authority of the Surrogate's Court to address estate-related disputes as they arise, without being unduly constrained by procedural formalities. This flexibility helps ensure that estate matters can be handled comprehensively and efficiently, preventing unnecessary delays caused by rigid jurisdictional rules.