Legal Memorandum: Conditions for Contract Claims in NY

Issue: When and where do contract claims accrue in New York?

Area of Law: Business Organizations & Contracts, Litigation & Procedure
Keywords: Contract claim; Accrual; Economic injury
Jurisdiction: New York
Cited Cases: 715 N.E.2d 482; 693 N.Y.S.2d 479; 93 N.Y.S.2d 525
Cited Statutes: N.Y. C.P.L.R. 202 Practice Commentary (1999)
Date: 04/01/2013

N.Y. C.P.L.R. 202 Practice Commentary (1999) ("A contract claim accrues at the time when, and in the place where, the plaintiff sustained the alleged injury" (citing Global Fin. Corp. v. Triarc, 93 N.Y.S.2d 525, 693 N.Y.S.2d 479, 715 N.E.2d 482 (1999)).
Id.  ("When the alleged injuries are purely economic, as in a contract case, 'the place of injury usually is where the plaintiff resides and sustains the economic impact of the loss." (quoting Global Fin. Corp., 93 N.Y.2d at 529, 693 N.Y.S.2d at 482, 715 N.E.2d at 486)).


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