Appellate Division, Second Department · September 30, 2026 · 2026 NY Slip Op 05512
Board of Educ. of the Blind Brook-Rye Union Free Sch. Dist. v Kliment Halsband Architects
Read the official decision: 2026 NY Slip Op 05512
Holding The court affirmed the dismissal of negligence, fraudulent misrepresentation, and punitive damages claims because they were duplicative of the breach of contract claim. The court found that the plaintiff was seeking the benefit of its bargain and failed to allege an independent tort or duty separate from the contract.
The court’s words
A simple breach of contract is not to be considered a tort unless a legal duty independent of the contract itself has been violated
2026 NY Slip Op 05512, at the official text
New York does not recognize an independent cause of action for punitive damages
2026 NY Slip Op 05512, at the official text
Punitive damages are not recoverable for an ordinary breach of contract as their purpose is not to remedy private wrongs but to vindicate public rights
2026 NY Slip Op 05512, at the official text
| Court | Appellate Division, Second Department |
|---|---|
| Decided | September 30, 2026 |
| Citation | 2026 NY Slip Op 05512 |
| Area of law | Contracts and Commercial |
| Week | Week ending October 3, 2026 |
| Official text | Official decision: 2026 NY Slip Op 05512 |
| Publication status | Slip opinions are uncorrected and subject to revision before publication in the Official Reports. |
| Source feed | New York slip opinion page |
| Law Watch record id | 687 |
Recommended citation
ESQ HQ, New York Law Watch, Board of Educ. of the Blind Brook-Rye Union Free Sch. Dist. v Kliment Halsband Architects, 2026 NY Slip Op 05512 (Appellate Division, Second Department, September 30, 2026), https://esqhq.com/decisions/2026-ny-slip-op-05512/
How this record was made
Holding drafted by Law Watch’s in-house model, graded by three reviewers; every quotation verified word for word against the official text.
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