quasi-contractual claim (New York) · Go Syfert
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quasi-contractual claim in New York

14 New York opinions name it 4 courts 1984–2026 8 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 (11)

CaseFollowedCited
Clark-Fitzpatrick, Inc. v. Long Island Rail Roadgreen
ny · 1987 · cited in 2 New York opinions naming this issue, 2023–2024
2 sentences

2023But a quasi-contractual claim "only applies in the absence of an express agreement, and it is not really a contract at all, but rather a legal obligation imposed to prevent a party's unjust enrichment" ( Clark-Fitzpatrick , 70 NY2d at 388). "[A] quasi-contractual obligation is one imposed by law where there has been no agreement or expression of assent, by word or act, on the part of either party involved .

2023But a quasi-contractual claim "only applies in the absence of an express agreement, and it is not really a contract at all, but rather a legal obligation imposed to prevent a party's unjust enrichment" ( Clark-Fitzpatrick , 70 NY2d at 388 ). "[A] quasi-contractual obligation is one imposed by law where there has been no agreement or expression of assent, by word or act, on the part of either party involved .

22
People v. Arroyogreen
nyappdiv · 2008 · cited in 2 New York opinions naming this issue, 2023–2023
2 sentences

2023Co. II LLC v Shanahan , 49 AD3d 403, 405 [1st Dept 2008]).

2023Co. II LLC v Shanahan , 49 AD3d 403, 405 [1st Dept 2008]).

22
Kaminsky v. Herrickgreen
nyappdiv · 2008 · cited in 2 New York opinions naming this issue, 2014–2014
2 sentences

2014The cause of action based upon Judiciary Law § 487 was properly dismissed since relief under this statute is not lightly given and the conduct alleged does not establish the existence of a chronic and/or extreme pattern of legal delinquency which caused damages (see Kaminsky v Herrick, Feinstein LLP, 59 AD3d 1, 13 [1st Dept 2008], lv denied 12 NY3d 715 [2009]; Nason v Fisher, 36 AD3d 486, 487 [1st Dept 2007]).

2014The cause of action based upon Judiciary Law § 487 was properly dismissed since relief under this statute is not lightly given and the conduct alleged does not establish the existence of a chronic and/or extreme pattern of legal delinquency which caused damages (see Kaminsky v Herrick, Feinstein LLP, 59 AD3d 1, 13 [1st Dept 2008], lv denied 12 NY3d 715 [2009]; Nason v Fisher, 36 AD3d 486, 487 [1st Dept 2007]).

22
Nason v. Fishergreen
nyappdiv · 2007 · cited in 2 New York opinions naming this issue, 2014–2014
2 sentences

2014The cause of action based upon Judiciary Law § 487 was properly dismissed since relief under this statute is not lightly given and the conduct alleged does not establish the existence of a chronic and/or extreme pattern of legal delinquency which caused damages (see Kaminsky v Herrick, Feinstein LLP, 59 AD3d 1, 13 [1st Dept 2008], lv denied 12 NY3d 715 [2009]; Nason v Fisher, 36 AD3d 486, 487 [1st Dept 2007]).

2014The cause of action based upon Judiciary Law § 487 was properly dismissed since relief under this statute is not lightly given and the conduct alleged does not establish the existence of a chronic and/or extreme pattern of legal delinquency which caused damages (see Kaminsky v Herrick, Feinstein LLP, 59 AD3d 1, 13 [1st Dept 2008], lv denied 12 NY3d 715 [2009]; Nason v Fisher, 36 AD3d 486, 487 [1st Dept 2007]).

22
Wilmoth v. Sandorgreen
nyappdiv · 1999 · cited in 2 New York opinions naming this issue, 2014–2014
2 sentences

2014However, we find that, as a dispute exists as to the application of the retainer agreement as to defendant, plaintiffs need not elect their remedies and may pursue a quasi-contractual claim for unjust enrichment, as an alternative claim (see Wilmoth v Sandor, 259 AD2d 252, 254 [1st Dept 1999]).

2014However, we find that, as a dispute exists as to the application of the retainer agreement as to defendant, plaintiffs need not elect their remedies and may pursue a quasi-contractual claim for unjust enrichment, as an alternative claim (see Wilmoth v Sandor, 259 AD2d 252, 254 [1st Dept 1999]).

22
IDT Corp. v. Morgan Stanley Dean Witter & Co.green
ny · 2009 · cited in 2 New York opinions naming this issue, 2011–2026
2 sentences

2026Unjust enrichment, a quasi-contractual claim, "is an obligation imposed by equity to prevent injustice, in the absence of an actual agreement between the parties concerned" ( IDT Corp. v Morgan Stanley Dean Witter & Co. , 12 NY3d 132, 142 , rearg denied 12 NY3d 889 ).

2011Plaintiffs also fail to state a cause of action for unjust enrichment, a quasi-contractual claim based on the principle that a person should not be allowed to enrich himself or herself at the expense of another (see IDT Corp. v Morgan Stanley Dean Witter & Co., 12 NY3d 132, 142 [2009]).

12
Chowaiki & Co. Fine Art Ltd. v. Lachergreen
nyappdiv · 2014 · cited in 1 New York opinions naming this issue, 2025–2025
2 sentences

2025While Baker Botts asserts that this claim should be dismissed as duplicative of the dismissed legal malpractice claim ( see Ullmann-Schneider v Lacher & Lovell-Taylor, P.C. , 121 AD3d 415, 416 [1st Dept 2014]), absent the written retainer agreement, which was not included in the record on appeal, a defense as to the scope of its representation cannot conclusively be established ( see Weil, Gotshal & Manges, LLP v Fashion Boutique of Short Hills, Inc. , 10 AD3d 267, 270-271 [1st Dept 2004]). "[A]s a dispute exists as to the application of the retainer agreement as to defendant, plaintiffs need

2025While Baker Botts asserts that this claim should be dismissed as duplicative of the dismissed legal malpractice claim ( see Ullmann-Schneider v Lacher & Lovell-Taylor, P.C. , 121 AD3d 415, 416 [1st Dept 2014]), absent the written retainer agreement, which was not included in the record on appeal, a defense as to the scope of its representation cannot conclusively be established ( see Weil, Gotshal & Manges, LLP v Fashion Boutique of Short Hills, Inc. , 10 AD3d 267, 270-271 [1st Dept 2004]). "[A]s a dispute exists as to the application of the retainer agreement as to defendant, plaintiffs need

11
Weil, Gotshal & Manges, LLP v. Fashion Boutique of Short Hills, Inc.green
nyappdiv · 2004 · cited in 1 New York opinions naming this issue, 2025–2025
2 sentences

2025While Baker Botts asserts that this claim should be dismissed as duplicative of the dismissed legal malpractice claim ( see Ullmann-Schneider v Lacher & Lovell-Taylor, P.C. , 121 AD3d 415, 416 [1st Dept 2014]), absent the written retainer agreement, which was not included in the record on appeal, a defense as to the scope of its representation cannot conclusively be established ( see Weil, Gotshal & Manges, LLP v Fashion Boutique of Short Hills, Inc. , 10 AD3d 267, 270-271 [1st Dept 2004]). "[A]s a dispute exists as to the application of the retainer agreement as to defendant, plaintiffs need

2025While Baker Botts asserts that this claim should be dismissed as duplicative of the dismissed legal malpractice claim ( see Ullmann-Schneider v Lacher & Lovell-Taylor, P.C. , 121 AD3d 415, 416 [1st Dept 2014]), absent the written retainer agreement, which was not included in the record on appeal, a defense as to the scope of its representation cannot conclusively be established ( see Weil, Gotshal & Manges, LLP v Fashion Boutique of Short Hills, Inc. , 10 AD3d 267, 270-271 [1st Dept 2004]). "[A]s a dispute exists as to the application of the retainer agreement as to defendant, plaintiffs need

11
Ullmann-Schneider v. Lacher & Lovell-Taylor, P.C.green
nyappdiv · 2014 · cited in 1 New York opinions naming this issue, 2025–2025
2 sentences

2025While Baker Botts asserts that this claim should be dismissed as duplicative of the dismissed legal malpractice claim ( see Ullmann-Schneider v Lacher & Lovell-Taylor, P.C. , 121 AD3d 415, 416 [1st Dept 2014]), absent the written retainer agreement, which was not included in the record on appeal, a defense as to the scope of its representation cannot conclusively be established ( see Weil, Gotshal & Manges, LLP v Fashion Boutique of Short Hills, Inc. , 10 AD3d 267, 270-271 [1st Dept 2004]). "[A]s a dispute exists as to the application of the retainer agreement as to defendant, plaintiffs need

2025While Baker Botts asserts that this claim should be dismissed as duplicative of the dismissed legal malpractice claim ( see Ullmann-Schneider v Lacher & Lovell-Taylor, P.C. , 121 AD3d 415, 416 [1st Dept 2014]), absent the written retainer agreement, which was not included in the record on appeal, a defense as to the scope of its representation cannot conclusively be established ( see Weil, Gotshal & Manges, LLP v Fashion Boutique of Short Hills, Inc. , 10 AD3d 267, 270-271 [1st Dept 2004]). "[A]s a dispute exists as to the application of the retainer agreement as to defendant, plaintiffs need

11
Leon v. Martinezgreen
ny · 1994 · cited in 1 New York opinions naming this issue, 2023–2023
2 sentences

2023LEGAL STANDARD On a motion to dismiss pursuant to CPLR 3211, "the pleading is to be afforded a liberal construction" and the court must "accept the facts as alleged in the complaint as true, accord plaintiffs the benefit of every possible favorable inference, and determine only whether the facts as alleged fit within any cognizable legal theory" ( Leon v. Martinez , 84 NY2d 83, 87-88 [1994]).

2023LEGAL STANDARD On a motion to dismiss pursuant to CPLR 3211, "the pleading is to be afforded a liberal construction" and the court must "accept the facts as alleged in the complaint as true, accord plaintiffs the benefit of every possible favorable inference, and determine only whether the facts as alleged fit within any cognizable legal theory" ( Leon v. Martinez , 84 NY2d 83, 87-88 [1994]).

11
Bradkin v. Levertongreen
ny · 1970 · cited in 1 New York opinions naming this issue, 2023–2023
1 sentence

2023The law creates it . . . to assure a just and equitable result" ( Bradkin v Leverton , 26 NY2d 192, 196 [1970]).

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 (6)

CaseCitedYears
Kaminsky v. HERRICK, FEINSTEIN LLP green
ny · 2009
2 sentences

2014The cause of action based upon Judiciary Law § 487 was properly dismissed since relief under this statute is not lightly given and the conduct alleged does not establish the existence of a chronic and/or extreme pattern of legal delinquency which caused damages (see Kaminsky v Herrick, Feinstein LLP, 59 AD3d 1, 13 [1st Dept 2008], lv denied 12 NY3d 715 [2009]; Nason v Fisher, 36 AD3d 486, 487 [1st Dept 2007]).

2014The cause of action based upon Judiciary Law § 487 was properly dismissed since relief under this statute is not lightly given and the conduct alleged does not establish the existence of a chronic and/or extreme pattern of legal delinquency which caused damages (see Kaminsky v Herrick, Feinstein LLP, 59 AD3d 1, 13 [1st Dept 2008], lv denied 12 NY3d 715 [2009]; Nason v Fisher, 36 AD3d 486, 487 [1st Dept 2007]).

22014–2014
Vescon Construction, Inc. v. Gerelli Insurance Agency, Inc. neutral
nyappdiv · 2012
2 sentences

2014Agency, Inc., 97 AD3d 658 [2012]; Shovak v Long Is.

2014Agency, Inc., 97 AD3d 658 [2012]; Shovak v Long Is.

22014–2014
Woss, LLC v. 218 Eckford, LLC green
nyappdiv · 2013
2 sentences

2014A cause of action alleging unjust enrichment is a quasi-contractual claim that is not viable where, as here, the parties entered into an express contract governing the subject of dispute which, here, involves the execution of a mortgage on the 17th Avenue property (see Woss, LLC v 218 Eckford, LLC, 102 AD3d 860 [2013]; Vescon Constr., Inc. v Gerelli Ins.

2014A cause of action alleging unjust enrichment is a quasi-contractual claim that is not viable where, as here, the parties entered into an express contract governing the subject of dispute which, here, involves the execution of a mortgage on the 17th Avenue property (see Woss, LLC v 218 Eckford, LLC, 102 AD3d 860 [2013]; Vescon Constr., Inc. v Gerelli Ins.

22014–2014
People v. Carr green
ny · 2009
1 sentence

2026Unjust enrichment, a quasi-contractual claim, "is an obligation imposed by equity to prevent injustice, in the absence of an actual agreement between the parties concerned" ( IDT Corp. v Morgan Stanley Dean Witter & Co. , 12 NY3d 132, 142 , rearg denied 12 NY3d 889 ).

12026–2026
Crocker Commercial Services, Inc. v. Davan Enterprises, Inc. green
nyappdiv · 1982
1 sentence

1984Realty, 88 AD2d 877 , affd 57 NY2d 1038 .) Nor does it appear even inferentially that defendants have breached any implied or constructive duty to plaintiffs, and no basis for a quasi-contractual claim is thus presented.

11984–1984
Tribune Printing Co., Inc. v. 263 Ninth Ave. Realty, Inc. green
ny · 1982
1 sentence

1984Realty, 88 AD2d 877 , affd 57 NY2d 1038 .) Nor does it appear even inferentially that defendants have breached any implied or constructive duty to plaintiffs, and no basis for a quasi-contractual claim is thus presented.

11984–1984

Where else courts name it

IL 15 (1982–2020) PA 15 (1938–2026) NY 14 (1984–2026) TX 12 (1990–2024) OR 8 (1994–2016) MD 5 (1984–2023) LA 3 (1989–2014) OH 3 (2016–2025) DC 3 (1950–2005) AR 3 (1971–2016) CO 3 (1989–2014) AL 2 (1996–2000) AZ 2 (1980–2004) MO 2 (2004–2024) CA 2 (2017–2017) DE 2 (2025–2025) VT 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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