On May 2, 2025, Justice Patel of the New York County Commercial Division issued a decision in Gehl Foods, LLC v. Worldwide Sport Nutritional Supplements, Inc., 2025 NY Slip Op. 31602(U), holding that a party is a prevailing party for purposes of an attorneys’ fees award when it obtained the central relief it sought, explaining:
To determine whether a party has prevailed for the purpose of awarding attorneys’ fees, the court must consider the true scope of the dispute litigated and what was achieved within that scope. To be considered a prevailing party, one must simply prevail on the central claims advanced, and receive substantial relief in consequence thereof. Plaintiff’s reliance on inapposite landlord-tenant and summary proceeding cases, including J.P. & Assocs. Props. Corp. v. Krautter, 38 Misc. 3d 60 (App. Term 2d Dept 2013), is misplaced. In those cases, dismissals left unresolved central claims and expressly contemplated future litigation. For example, in Krautter, the petition was dismissed without prejudice while a related DHCR proceeding remained pending. The court held that a prevailing party determination was premature because the ultimate outcome of the controversy had not been reached.
The Court finds that Defendant have established that it is the prevailing party because the Court adjudicated the central relief sought by Defendant on the merits and has disposed of Plaintiff’s singular claim for breach of the Pilot Agreement. Contrary to Plaintiff’s arguments, the Court’s dismissal of the action was not based on a procedural defect or technicality, but rather on a dispositive legal ruling that resolved the central relief sought. The Court held that the Pilot Agreement could not be orally modified under General Obligations Law § 15-301 and the purchase orders at issue constituted fully integrated agreements, thereby barring extrinsic evidence under U.C.C. § 2-202. The Court further held that Plaintiff failed to identify any specific contractual obligation that was breached. Plaintiff has not appealed, sought leave to replead, and/or filed or continued any action alleging breach of the Pilot Agreement.
Accordingly, there is nothing left to adjudicate, and no other proceeding exists or is anticipated that could alter the outcome of this litigation.
(Internal quotations and citations omitted).