New York Court of Appeals

Joseph Lanzi, Appellant v. Arthur Brooks, Respondent

December 15, 197743 N.Y.2d 778

Summary

The New York Court of Appeals affirmed the Appellate Division, holding that the plaintiff's complaint failed to allege a present intent not to perform future promises and therefore did not state a cause of action for fraud based on a misstatement of future intentions; the court also clarified that CPLR 3016(b) requires only sufficient detail, not strict detail, to plead fraud.