Kyle Connaughton, Appellant v. Chipotle Mexican Grill, Inc., Respondents

Summary

The New York Court of Appeals affirmed the Appellate Division’s dismissal of the plaintiff’s fraudulent inducement claim, holding that the complaint failed to allege any out‑of‑pocket pecuniary loss and therefore did not state a viable cause of action. The Court also ruled that nominal damages are unavailable where actual harm is an element of the tort and that discovery cannot cure a pleading defect based on speculative damages.