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10 New York opinions name it 3 courts 1924–2025 3 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 |
|---|---|---|
Parma Tile Mosaic & Marble Co. v. Shortgreen2 sentences2025The alleged contract, which the parties do not dispute falls within the ambit of the statute of frauds, is also unenforceable because the set of text messages that collectively form the alleged agreement failed to comport with the statute of fraud's subscription requirement ( see Parma Tile Mosaic & Marble Co. v Estate of Short , 87 NY2d 524, 527-528 [1996]; cf . 2025The alleged contract, which the parties do not dispute falls within the ambit of the statute of frauds, is also unenforceable because the set of text messages that collectively form the alleged agreement failed to comport with the statute of fraud's subscription requirement ( see Parma Tile Mosaic & Marble Co. v Estate of Short , 87 NY2d 524, 527-528 [1996]; cf . | 1 | 4 |
Page v. Muze, Inc.green2 sentences2010Cf. MP Innovations, Inc. v Atlantic Horizon Intl., Inc., 72 AD3d 571, 572 (2010) (e-mail did not satisfy the statute of frauds because it failed to “identify a number of material terms” of the alleged agreement); Page v Muze, Inc., 270 AD2d 401, 401 (2000) (e-mail did not satisfy the statute of frauds where it “made only an equivocal reference” to the right claimed by plaintiff and “was not shown to have satisfied the subscription requirement”). . 2007“The fax transmission in Parma did not satisfy the statute of frauds because there was never any demonstration of the sender’s specific intent to authenticate it and not because it was electronically transmitted.” (Rosenfeld at 195 .) In Page v Muze, Inc. ( 270 AD2d 401 [2000]), the Court held that “a typewritten signature does not satisfy the subscription requirement of the former statute of frauds provision contained in the Uniform Commercial Code (UCS 8-319, as repealed by L 1997, ch 566, § 5).” (Rosenfeld at 196 [emphasis added].) “The rationale for that decision,” Justice Kramer wrote, “m | 1 | 4 |
MP Innovations, Inc. v. Atlantic Horizon International, Inc.green1 sentence2010Cf. MP Innovations, Inc. v Atlantic Horizon Intl., Inc., 72 AD3d 571, 572 (2010) (e-mail did not satisfy the statute of frauds because it failed to “identify a number of material terms” of the alleged agreement); Page v Muze, Inc., 270 AD2d 401, 401 (2000) (e-mail did not satisfy the statute of frauds where it “made only an equivocal reference” to the right claimed by plaintiff and “was not shown to have satisfied the subscription requirement”). . | 1 | 1 |
Rosenfeld v. Zerneckgreen1 sentence2007“The fax transmission in Parma did not satisfy the statute of frauds because there was never any demonstration of the sender’s specific intent to authenticate it and not because it was electronically transmitted.” (Rosenfeld at 195 .) In Page v Muze, Inc. ( 270 AD2d 401 [2000]), the Court held that “a typewritten signature does not satisfy the subscription requirement of the former statute of frauds provision contained in the Uniform Commercial Code (UCS 8-319, as repealed by L 1997, ch 566, § 5).” (Rosenfeld at 196 [emphasis added].) “The rationale for that decision,” Justice Kramer wrote, “m | 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 |
|---|---|---|
Papakostas v. Harkins
green
2 sentences2009At best, the e-mail was the equivalent of a cover letter to a proposed contract, the signing of which is insufficient to satisfy the subscription requirement (see Papakostas v Harkins, 168 AD2d 547 [1990]). 2009At best, the e-mail was the equivalent of a cover letter to a proposed contract, the signing of which is insufficient to satisfy the subscription requirement (see Papakostas v Harkins, 168 AD2d 547 [1990]). | 1 | 2009–2009 |
Bowling v. Pedzik
green
1 sentence2009In any event, an agent may only bind a party to a real estate contract if authorized to do so in writing (see General Obligations Law § 5-703 [2]; Bowling v Pedzik, 302 AD2d 343 [2003]). | 1 | 2009–2009 |
Trent Import Co. v. Wheelwright
neutral
1 sentence1924(Foley v. Speir, 100 N. Y. 552 ; Trent Import Co. v. Wheelwright, supra.) The further question remains as to whether the objection that the subscription is in violation of the statute may be urged by the subscriber in an action brought by a receiver. | 1 | 1924–1924 |
Foley v. . Speir
neutral
1 sentence1924(Foley v. Speir, 100 N. Y. 552 ; Trent Import Co. v. Wheelwright, supra.) The further question remains as to whether the objection that the subscription is in violation of the statute may be urged by the subscriber in an action brought by a receiver. | 1 | 1924–1924 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
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.