On April 27, 2023, the First Department issued a decision in National Union Fire Ins. Co. of Pittsburgh, PA v. Rudell & Assoc., Inc., 2023 NY Slip Op. 02183, holding that an extortion defense fails without evidence of threats of unlawful injury, explaining:
The Rudell defendants are not entitled to assert extortion as a defense to plaintiffs’ claims against them. They admitted that they were never threatened and, in any event, did not show that any threats made by Razzouk to induce the bribe payments constituted threats of unlawful injury.
(Internal citations omitted).