New York Court of Appeals

Georgia Malone & Company, Inc. v. Ralph Rieder, and Rosewood Realty Group, Inc.

June 28, 201219 N.Y.3d 511

Summary

The New York Court of Appeals affirmed the Appellate Division’s order dismissing Malone’s unjust enrichment claim against Rosewood, holding that the alleged relationship between the parties was too attenuated to support liability. The Court emphasized that mere knowledge of the plaintiff’s work and an arm‑length transaction are insufficient. A dissent argued the claim should proceed, but it does not affect the holding.