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5 New York opinions name it 2 courts 2008–2019 0 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.
| Case | Followed | Cited |
|---|---|---|
Sardanis v. Sumitomo Corp.green1 sentence2014(Compare Niagara Mohawk Power Corp. v Freed, 265 AD2d 938 , 939 [1999] [“Contrary to defendants’ contention, commercial bribery can constitute a civil cause of action”], with Sardanis v Sumitomo Corp., 279 AD2d 225, 230 [1st Dept 2001] [deeming no private right of action under the commercial bribery provisions of the Penal Law “notwithstanding a contrary ruling by the Fourth Department in Niagara Mohawk Power Corp. v Freed”].) Thus, in the First Department, “commercial bribery” does not constitute an “independent tort” and cannot be considered a “wrongful means” on this ground. | 1 | 1 |
Jacobs v. Kaygreen1 sentence2010Even apart from Ford and Hahn , this Court has held that a viable tort claim against a professional requires the underlying relationship between the parties to be one of contract or the bond between them so close as to be the functional equivalent of contractual privity (Jacobs v Kay, 50 AD3d 526, 527 [2008], citing Ossining Union Free School Dist. v Anderson LaRocca Anderson, 73 NY2d 417 [1989]). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Ossining Union Free School District v. Anderson
green
2 sentences2010Even apart from Ford and Hahn , this Court has held that a viable tort claim against a professional requires the underlying relationship between the parties to be one of contract or the bond between them so close as to be the functional equivalent of contractual privity (Jacobs v Kay, 50 AD3d 526, 527 [2008], citing Ossining Union Free School Dist. v Anderson LaRocca Anderson, 73 NY2d 417 [1989]). 2008A viable tort claim against a professional requires that the underlying relationship between the parties be one of contract or the bond between them so close as to be the functional equivalent of contractual privity (Ossining Union Free School Dist. v Anderson LaRocca Anderson, 73 NY2d 417 [1989]). | 2 | 2008–2010 |
Thome v. Alexander & Louisa Calder Foundation
green
1 sentence2019In the absence of a viable tort claim, there can be no conspiracy claim ( Thome , 70 AD3d at 110 ). | 1 | 2019–2019 |
Niagara Mohawk Power Corp. v. Freed
green
1 sentence2014(Compare Niagara Mohawk Power Corp. v Freed, 265 AD2d 938 , 939 [1999] [“Contrary to defendants’ contention, commercial bribery can constitute a civil cause of action”], with Sardanis v Sumitomo Corp., 279 AD2d 225, 230 [1st Dept 2001] [deeming no private right of action under the commercial bribery provisions of the Penal Law “notwithstanding a contrary ruling by the Fourth Department in Niagara Mohawk Power Corp. v Freed”].) Thus, in the First Department, “commercial bribery” does not constitute an “independent tort” and cannot be considered a “wrongful means” on this ground. | 1 | 2014–2014 |
Mannix Industries, Inc. v. Antonucci
green
1 sentence2009Co. v Village of Broadalbin, 302 AD2d 640 [2003]; Mc-Nar Indus. v Feibes & Schmitt, Architects, 245 AD2d 993 [1997]; Mannix Indus, v Antonucci, 191 AD2d 482 [1993]). | 1 | 2009–2009 |
McNar Industries, Inc. v. Feibes & Schmitt, Architects
green
1 sentence2009Co. v Village of Broadalbin, 302 AD2d 640 [2003]; Mc-Nar Indus. v Feibes & Schmitt, Architects, 245 AD2d 993 [1997]; Mannix Indus, v Antonucci, 191 AD2d 482 [1993]). | 1 | 2009–2009 |
Marcellus Construction Co. v. Village of Broadalbin
green
1 sentence2009Co. v Village of Broadalbin, 302 AD2d 640 [2003]; Mc-Nar Indus. v Feibes & Schmitt, Architects, 245 AD2d 993 [1997]; Mannix Indus, v Antonucci, 191 AD2d 482 [1993]). | 1 | 2009–2009 |
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.