On January 30, 2025, the First Department issued a decision in G & Y Maintenance Corp. v. 540 W. 48th St. Corp., 2025 NY Slip Op. 00481, holding that amended claims did not relate back when they arose from different facts and implicated different duties from earlier ones, explaining:
Supreme Court providently exercised its discretion in allowing the amendment to add the cause of action for breach of contract, as limited by the court to two paragraphs in the parties’ agreement. The proposed cause of action sufficiently pleads the elements of breach of contract.
However, the court should not have granted leave for plaintiff to assert the fraudulent conveyance causes of action. Neither party disputes that those claims are barred by the six-year statute of limitations unless the relation-back doctrine applies. We reject plaintiff’s argument that it satisfied the requirements of the relation-back doctrine under CPLR 203(c). The new fraudulent conveyance claims arise from different facts and implicate different duties from the ones previously raised, and therefore go beyond mere amplification of the pleadings.
(Internal citations omitted).