CPLR 5203(a) gives priority to a judgment creditor over subsequent transferees with regard to the debtor's real property where the judgment was docketed with the county clerk. Pursuant to CPLR 5018(c), a judgment is docketed when the clerk makes an entry "under the surname of the judgment debtor, . . . consist[ing] of . . . the name and last known address of [the] judgment debtor." Once docketed, the judgment becomes a lien on the property. Here, the judgment was not docketed under the correct surnames of the title owners of the property, and, therefore, there is no valid lien.
Kunin v. Guttman, NY Slip Op 02044 (2d Dep't March 25, 2020)
Here is the decision.