The Moore Charitable Foundation v. PJT Partners

Summary

The Court of Appeals held that plaintiffs adequately pleaded negligent supervision and retention against an investment bank whose employee allegedly used his position, employer resources, and access to confidential information to defraud them of $25 million. The complaint sufficiently alleged constructive notice because the employer allegedly failed to investigate a missing deal fee and the employee's implausible explanation before the later fraud occurred. The Court also held that a customer or privity relationship is not required where plaintiffs were directly harmed by tortious conduct enabled by the employee's employment. The order dismissing the claim was reversed.