party asserting the affirmative defense (New York) · Go Syfert
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party asserting the affirmative defense in New York

9 New York opinions name it 5 courts 1999–2022 1 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 (8)

CaseFollowedCited
Profex, Inc. v. Town of Fishkillgreen
nyappdiv · 2009 · cited in 3 New York opinions naming this issue, 2017–2022
2 sentences

2022The party asserting the affirmative defense of accord and satisfaction bears the burden of establishing "that there was a disputed or unliquidated claim between the parties which they mutually resolved through a new contract discharging all or part of their obligations under the original contract" ( Profex, Inc. v Town of Fishkill , 65 AD3d 678, 678 [2009]).

2018The party asserting the affirmative defense of accord and satisfaction bears the burden of establishing "that there was a disputed or unliquidated claim between the parties which they mutually resolved through a new contract discharging all or part of their obligations under the original contract" ( Profex, Inc. v Town of Fishkill , 65 AD3d 678 , 678 [2009]).

23
Merrill Lynch Realty/Carll Burr, Inc. v. Skinnergreen
ny · 1984 · cited in 2 New York opinions naming this issue, 2009–2022
2 sentences

2022"As a general rule, acceptance of a check in full settlement of a disputed unliquidated claim operates as an [*2]accord and satisfaction discharging the claim" ( Merrill Lynch Realty/Carll Burr, Inc. v Skinner , 63 NY2d 590, 596 [1984]).

2009The party asserting the affirmative defense of accord and satisfaction must establish that there was a disputed or unliquidated claim between the parties which they mutually resolved through a new contract discharging all or part of their obligations under the original contract (see Merrill Lynch Realty/Carll Burr, Inc. v Skinner, 63 NY2d 590, 596 [1984]; Pothos v Arverne Houses, 269 AD2d 377, 378 [2000]; Trans World Grocers v Sultana Crackers, 257 AD2d 616, 617 [1999]).

22
Schnell v. . Perlmongreen
ny · 1924 · cited in 2 New York opinions naming this issue, 1999–1999
2 sentences

1999A genuine dispute requires that the debtor give notice of the dispute prior to tendering a partial payment in full satisfaction (see, Century 21 Kaaterskill Realty v Grasso, 124 AD2d 316 ; see, Schnell v Perlmon, 238 NY 362 ; Fuller v Kemp, 138 NY 231 ; Schuttinger v Woodruff, 259 NY 212 ).

1999A genuine dispute requires that the debtor give notice of the dispute prior to tendering a partial payment in full satisfaction (see, Century 21 Kaaterskill Realty v Grasso, 124 AD2d 316 ; see, Schnell v Perlmon, 238 NY 362 ; Fuller v Kemp, 138 NY 231 ; Schuttinger v Woodruff, 259 NY 212 ).

22
Horn Waterproofing Corp. v. Bushwick Iron & Steel Co.green
ny · 1985 · cited in 3 New York opinions naming this issue, 1999–2017
2 sentences

1999The party asserting the affirmative defense of accord and satisfaction must establish that there was a genuine dispute regarding an unliquidated claim between the parties which they mutually resolved through a new contract discharging all or part of their obligations under the original contract (see, Horn Waterproofing Corp. v Bushwick Iron & Steel Co., supra).

1999The party asserting the affirmative defense of accord and satisfaction must establish that there was a genuine dispute regarding an unliquidated claim between the parties which they mutually resolved through a new contract discharging all or part of their obligations under the original contract (see, Horn Waterproofing Corp. v Bushwick Iron & Steel Co., supra).

13
Radin v. Radingreen
nyappdiv · 1994 · cited in 1 New York opinions naming this issue, 2017–2017
1 sentence

2017(Schulman v Schulman, 101 AD3d 1098 [2012].) Furthermore, the doctrine of constructive emancipation includes a child of employable age who abandons the noncustodial parent by refusing all contact; however, “[a] child’s reluctance to see a parent is not abandonment” thereby, relieving the parent of their support obligation (Radin v Radin, 209 AD2d 396, 396 [1994]).

11
People v. Delvasgreen
nyappdiv · 1996 · cited in 1 New York opinions naming this issue, 2017–2017
1 sentence

2017The indorsement of a check with the notation “under protest,” or similar wording, constitutes an explicit reservation of rights which precludes an accord and satisfaction (UCC former 1-207 [internal quotation marks omitted]; see Horn Waterproofing Corp. v Bushwick Iron & Steel Co., 66 NY2d 321, 332 [1985]; Metropolitan Knitwear v Trans World Fashions, 233 AD2d 241, 242 [1996]).

11
Selamaj v. City of New Yorkgreen
nyappdiv · 1999 · cited in 1 New York opinions naming this issue, 2009–2009
1 sentence

2009The party asserting the affirmative defense of accord and satisfaction must establish that there was a disputed or unliquidated claim between the parties which they mutually resolved through a new contract discharging all or part of their obligations under the original contract (see Merrill Lynch Realty/Carll Burr, Inc. v Skinner, 63 NY2d 590, 596 [1984]; Pothos v Arverne Houses, 269 AD2d 377, 378 [2000]; Trans World Grocers v Sultana Crackers, 257 AD2d 616, 617 [1999]).

11
Pothos v. Arverne Houses, Inc.green
nyappdiv · 2000 · cited in 1 New York opinions naming this issue, 2009–2009
1 sentence

2009The party asserting the affirmative defense of accord and satisfaction must establish that there was a disputed or unliquidated claim between the parties which they mutually resolved through a new contract discharging all or part of their obligations under the original contract (see Merrill Lynch Realty/Carll Burr, Inc. v Skinner, 63 NY2d 590, 596 [1984]; Pothos v Arverne Houses, 269 AD2d 377, 378 [2000]; Trans World Grocers v Sultana Crackers, 257 AD2d 616, 617 [1999]).

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 (7)

CaseCitedYears
Fuller v. . Kemp green
ny · 1893
2 sentences

1999A genuine dispute requires that the debtor give notice of the dispute prior to tendering a partial payment in full satisfaction (see, Century 21 Kaaterskill Realty v Grasso, 124 AD2d 316 ; see, Schnell v Perlmon, 238 NY 362 ; Fuller v Kemp, 138 NY 231 ; Schuttinger v Woodruff, 259 NY 212 ).

1999A genuine dispute requires that the debtor give notice of the dispute prior to tendering a partial payment in full satisfaction (see, Century 21 Kaaterskill Realty v Grasso, 124 AD2d 316 ; see, Schnell v Perlmon, 238 NY 362 ; Fuller v Kemp, 138 NY 231 ; Schuttinger v Woodruff, 259 NY 212 ).

21999–1999
Schuttinger v. Woodruff green
ny · 1932
2 sentences

1999A genuine dispute requires that the debtor give notice of the dispute prior to tendering a partial payment in full satisfaction (see, Century 21 Kaaterskill Realty v Grasso, 124 AD2d 316 ; see, Schnell v Perlmon, 238 NY 362 ; Fuller v Kemp, 138 NY 231 ; Schuttinger v Woodruff, 259 NY 212 ).

1999A genuine dispute requires that the debtor give notice of the dispute prior to tendering a partial payment in full satisfaction (see, Century 21 Kaaterskill Realty v Grasso, 124 AD2d 316 ; see, Schnell v Perlmon, 238 NY 362 ; Fuller v Kemp, 138 NY 231 ; Schuttinger v Woodruff, 259 NY 212 ).

21999–1999
Century 21 Kaaterskill Realty v. Grasso neutral
nyappdiv · 1986
2 sentences

1999A genuine dispute requires that the debtor give notice of the dispute prior to tendering a partial payment in full satisfaction (see, Century 21 Kaaterskill Realty v Grasso, 124 AD2d 316 ; see, Schnell v Perlmon, 238 NY 362 ; Fuller v Kemp, 138 NY 231 ; Schuttinger v Woodruff, 259 NY 212 ).

1999A genuine dispute requires that the debtor give notice of the dispute prior to tendering a partial payment in full satisfaction (see, Century 21 Kaaterskill Realty v Grasso, 124 AD2d 316 ; see, Schnell v Perlmon, 238 NY 362 ; Fuller v Kemp, 138 NY 231 ; Schuttinger v Woodruff, 259 NY 212 ).

21999–1999
Huimin Sun v. Cai green
nyappdiv · 2017
1 sentence

2018"The party asserting the affirmative defense of accord and satisfaction must establish that there was a disputed or unliquidated claim between the parties which they mutually resolved through a new contract discharging all or part of their obligations under the original contract" ( Huimin Sun v Cai , 146 AD3d 760 , 762 [2d Dept 2017] [internal quotation marks and citation omitted]; see Rose Inn of Ithaca, Inc. v Great Am.

12018–2018
Schulman v. Schulman green
nyappdiv · 2012
1 sentence

2017(Schulman v Schulman, 101 AD3d 1098 [2012].) Furthermore, the doctrine of constructive emancipation includes a child of employable age who abandons the noncustodial parent by refusing all contact; however, “[a] child’s reluctance to see a parent is not abandonment” thereby, relieving the parent of their support obligation (Radin v Radin, 209 AD2d 396, 396 [1994]).

12017–2017
Ontario County Department of Social Services ex rel. Christopher L. v. Gail K. green
nyappdiv · 2000
1 sentence

2017(Matter of Ontario County Dept. of Social Servs. v Gail K., 269 AD2d 847 [2000].) The burden of proof rests upon the party asserting the affirmative defense of constructive emancipation.

12017–2017
Boyles v. Boyles green
nyappdiv · 1983
2 sentences

2005Matter of Boyles v. Boyles , 95 AD2d 95 , 466 NYS2d 762 .

2005Matter of Boyles v. Boyles , 95 AD2d 95 , 466 NYS2d 762 .

12005–2005

Where else courts name it

TX 26 (2000–2024) MO 14 (1999–2021) LA 10 (1987–2024) NY 9 (1999–2022) OH 4 (2019–2025) WY 4 (2016–2026) RI 4 (2005–2019) WA 3 (2021–2024) TN 3 (1987–2016) IN 3 (2003–2017) ID 3 (1993–2009) FL 3 (1988–2024) CT 3 (1994–2011) ME 3 (1984–2022) VT 2 (1986–2001) PA 2 (1998–2024) AL 2 (2007–2011) CO 2 (2001–2024)

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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