New York Court of Appeals

Richard E. Snyder, Appellant v. Edgar M. Bronfman, Jr., Respondent

November 23, 200913 N.Y.3d 504

Summary

The Court affirmed the Appellate Division’s dismissal, holding that the plaintiff’s quantum meruit and unjust enrichment claims for services in negotiating the Warner Music acquisition are barred by the statute of frauds in General Obligations Law § 5‑701(a)(10). The Court reasoned that the plaintiff’s activities fall squarely within the statutory definition of “negotiating” a business opportunity, and therefore require a written agreement.