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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
CourtAppellate Division, Second Department
DecidedSeptember 30, 2026
Citation2026 NY Slip Op 05512
Area of lawContracts and Commercial
WeekWeek ending October 3, 2026
Official textOfficial decision: 2026 NY Slip Op 05512
Publication statusSlip opinions are uncorrected and subject to revision before publication in the Official Reports.
Source feedNew York slip opinion page
Law Watch record id687

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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Published September 30, 2026. Updated September 30, 2026.