In 2017, the New York legislature amended CPLR 503(a) to provide
for venue in "[(1)] the county in which one of the parties
resided when it was commenced; [(2)] the county in which a
substantial part of the events or omissions giving rise to the
claim occurred; or, [(3)] if none of the parties then resided in
the state, in any county designated by the plaintiff."
Before the amendment, CPLR 503(a) did not provide for venue
based on where the events or omissions giving rise to the claim
occurred.
In Faustino
v. Amin,1 Justice Andrea Masley of the New York
Supreme Court, Commercial Division, analyzed the interesting
question of what happens when the plaintiff designates venue based
on residence and gets the defendants' residence wrong, but
venue is arguably proper anyway based on the location of the events
or omissions at issue. Justice Masley held that in this
scenario, the plaintiff can defeat a venue transfer demand by
submitting alternative grounds for the
