On October 4, 2024, the Fourth Department issued a decision in Liberty Maintenance, Inc. v. Alliant Ins. Servs., Inc., 2024 NY Slip op. 04871, holding that written contract’s integration clause barred a promissory estoppel claim based on an alleged oral modification of the written contract, explaining:
We agree with defendant that Supreme Court erred in denying the motion insofar as it sought dismissal of the fifth cause of action, for promissory estoppel, pursuant to CPLR 3211 (a) (1), and we therefore modify the order accordingly. The existence of a valid and enforceable written contract governing a particular subject matter ordinarily precludes recovery in quasi contract for events arising out of the same subject matter. Here, defendant established not only that the parties had a contract, i.e., the brokerage services agreement, but also that the agreement included an integration clause prohibiting modification of the agreement except by written amendment. We conclude that plaintiff has no tenable claim that it reasonably relied upon defendant’s alleged oral or implied promise in support of its promissory estoppel cause of action.
(Internal quotations and citations omitted).