On June 23, 2016, the First Department issued a decision in Gliklad v. Cherney, 2016 NY Slip Op. 05054, rejecting an argument that the trial court lacked jurisdiction to hold a litigant in contempt, explaining:
[Defendant] contends that the trial court lacked personal jurisdiction to issue the contempt order. By decision entered January 21, 2014, this Court previously found, as law of the case, that the promissory note contained a forum selection clause which subjected defendant to the jurisdiction of New York courts and barred him from asserting a defense of lack of jurisdiction. Through that appeal, defendant had a full and fair opportunity to address the jurisdiction issue.
After reviewing the record, this Court has determined that its prior decisions are not clearly erroneous requiring an abandonment of the law of the case doctrine. Nor has defendant contended that there is any new evidence or change of law warranting a different result.
(Internal quotations and citations omitted).