stand-alone claim (New York) · Go Syfert
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stand-alone claim in New York

5 New York opinions name it 3 courts 2017–2026 2 in the last five years

The cases below were cited by New York courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (2)

CaseFollowedCited
Enzien v. Enziengreen
nyappdiv · 2012 · cited in 1 New York opinions naming this issue, 2026–2026
1 sentence

2026However, "[a]lthough a stand-alone claim for unjust enrichment is barred where, as here, there is a valid written contract, that does not act as a bar to a constructive trust" cause of action ( Barker v Gervera , 236 AD3d 1318 , 1326 [citations omitted]; see Enzien v Enzien , 96 AD3d 1136 ).

11
Pennsylvania State Police v. Sudersgreen
scotus · 2004 · cited in 1 New York opinions naming this issue, 2017–2017
1 sentence

2017The United States Supreme Court has indicated that “[a] hostile-environment constructive discharge claim entails something more” than a stand-alone claim of a hostile work environment (Pennsylvania State Police v Suders, 542 US 129, 147 [2004]).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
Matter of Jacob green
ny · 1995
2 sentences

2017Finally, her due process argument is properly apprehended not as a stand-alone challenge requiring notice to the Attorney General, but as an invocation, in service of her jurisdictional challenge, of the canon of constitutional avoidance: that is, we should construe the statute, if possible, to avoid the due process infirmity to which she points ( see Matter of Jacob, 86 N.Y.2d 651 , 668 n. 5, 636 N.Y.S.2d 716 , 660 N.E.2d 397 [1995] ).

2017Finally, her due process argument is properly apprehended not as a stand-alone challenge requiring notice to the Attorney General, but as an invocation, in service of her jurisdictional challenge, of the canon of constitutional avoidance: that is, we should construe the statute, if possible, to avoid the due process infirmity to which she points ( see Matter of Jacob, 86 N.Y.2d 651 , 668 n. 5, 636 N.Y.S.2d 716 , 660 N.E.2d 397 [1995] ).

22017–2017
Hamrick v. Guralnick green
nyappdiv · 2017
1 sentence

2026In this case, unlike in Hamrick v Schain Leifer Guralnick ( 146 AD3d 606 ), cited by the majority, the plaintiff demonstrated a colorable claim to a fiduciary relationship between the parties based upon undisputed facts.

12026–2026
Cox v. NAP Constr. Co., Inc. green
ny · 2008
1 sentence

2025Although a stand-alone claim for unjust enrichment is barred where, as here, there is a valid written contract ( see IDT Corp. , 12 NY3d at 142 ; Cox, 10 NY3d at 607 ), that does not act as a bar to a constructive trust claim.

12025–2025
IDT Corp. v. Morgan Stanley Dean Witter & Co. green
ny · 2009
1 sentence

2025Although a stand-alone claim for unjust enrichment is barred where, as here, there is a valid written contract ( see IDT Corp. , 12 NY3d at 142 ; Cox, 10 NY3d at 607 ), that does not act as a bar to a constructive trust claim.

12025–2025

Where else courts name it

TN 15 (2009–2026) CA 12 (2009–2026) PA 12 (2008–2024) NC 10 (2019–2025) TX 9 (2009–2023) OR 8 (2020–2025) MD 7 (2013–2023) NY 5 (2017–2026) OH 4 (2007–2024) IA 4 (2002–2024) WV 4 (2012–2026) VI 4 (2014–2023) VA 3 (2002–2025) UT 3 (2014–2019) WA 3 (2015–2021) MT 3 (2002–2015) NM 3 (2018–2024) MI 3 (2014–2022) DE 2 (2021–2022) KY 2 (2011–2020) CO 2 (2013–2026) AR 2 (2006–2006)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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