Pludeman v. Northern Leasing Systems, Inc

In Pludeman v. Northern Leasing Systems, Inc., 10 NY3d 486, 890 N.E.2d 184, 860 N.Y.S.2d 422 (2008), the Court noted that the purpose of the CPLR pleading requirement "is to inform a defendant with respect to the incidents complained of.," but to strictly enforce such requirement would "prevent an otherwise valid cause of action in situations where it may be impossible to state in detail the circumstances constituting a fraud." Id. at 491. The Court observed that where the facts are peculiarly within the knowledge of the party charged with the fraud, it would be an injustice to dismiss a case at an early stage if the pleading deficiency could be cured later, after discovery. Id. While cautioning that CPLR 3016 (b) requires a complaint to sufficiently detail the fraud, the Court explained that such requirement "may be met when the facts are sufficient to permit a reasonable inference of the alleged conduct." Id., at 492.