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Fraud Claims Found to Be Duplicative of Contract Claim Because of An Overlap in Facts and Circumstances and Damages

In Crawford v. Integrated Asset Mgt. Servs., LLC, 2025 N.Y. Slip Op. 01352 (2d Dept. Mar. 12, 2025) (here), the Appellate Division, Second Department reversed the denial of the defendants’ motion to dismiss the plaintiffs’...more

Affidavit Fails To Establish That A Material Undisputed Fact Was Not A Fact At All, Says The First Department

In Katsorhis v. 718 W. Beech St, LLC, 2025 N.Y. Slip Op. 00211 (1st Dept. Jan. 15, 2025) (here), the Appellate Division, Second Department considered a fraud claim that the lower court sustained on the grounds that defendant...more

Summary Judgment Granted Because Reliance on Defendants’ Alleged Misrepresentations Was Not Justifiable

The justifiable reliance element has been described as a “fundamental precept” and a “venerable rule”. The requirement is one of the five elements of a fraud cause of action: (1) a misrepresentation or a material omission of...more

Thorny Issues Concerning the Statute of Limitations for Declaratory Relief and Breach of Fiduciary Duty

Statutes of limitations limit the time within which a defendant can be held liable for any type of alleged wrongdoing. Plaintiffs who do not pursue their rights within the limitations period will find the courthouse doors...more

Fraud Notes: Two Cases and The Examination of Scienter

To state a cause of action for fraud, a plaintiff must allege “a material misrepresentation of a fact, knowledge of its falsity, an intent to induce reliance, justifiable reliance by the plaintiff and damages.” The...more

Fraud Notes: Duplication, Failure to Identify Misrepresentations of Fact, and Fraudulent Concealment

On August 23, 2023, the Appellate Division, Second Department issued two decisions that briefly touched upon fraud causes of action: Hershman v. Bank of N.Y. Mellon, 2023 N.Y. Slip Op. 04369 (2d Dept. Aug. 22, 2023) (here),...more

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