Hannah Ehrlich v. American Moninger Greenhouse Manufacturing Corporation

Summary

The Court affirmed summary judgment for the plaintiff, holding that the parol evidence rule and CPLR 4519 do not bar the defendants' evidence and that the defendants failed to present sufficient evidence of an oral agreement negating consideration. The Court also held that CPLR 4519 does not preclude testimony in this case and that counterclaims are limited to the plaintiff's capacity, permitting the defendants only a separate action to seek a constructive trust.