Pursuant to RPAPL 1311 (1) the necessary defendants to a foreclosure action are "[e]very person having an estate or interest in possession, or otherwise, in the property as tenant in fee, for life, by the curtesy, or for years, and every person entitled to the reversion, remainder, or inheritance of the real property, or of any interest therein or undivided share thereof, after the determination of a particular estate therein." Where a property owner dies intestate, title to real property is automatically vested in the decedent's distributees.
Wilmington Sav. Fund Socy. v. Jsang Kei Lau, NY Slip Op 05504 (1st Dep't November 6, 2024)