Hayes v. Equality Specialities
Plaintiff Bonnie Hayes initiated an action against Equality Specialties, Inc., MNC Stribbons Inc., and MNC Sourcing Solutions, Inc., asserting claims of breach of contract, promissory estoppel, unjust enrichment, quantum meruit, and violations of New York Labor Law §§ 190-99, stemming from the termination of her employment by Equality. Her claims against MNC entities were predicated on a theory of successor liability for Equality's alleged wrongs. MNC moved for summary judgment, contending that Hayes failed to demonstrate a triable issue of fact regarding successor liability. The Court evaluated Hayes's arguments for de facto merger, implied assumption of liabilities, and fraud, ultimately finding insufficient evidence to establish any of these exceptions to the general rule against successor liability. Consequently, the Court granted MNC's motion for summary judgment, ordering Hayes to pursue a default judgment against Equality or dismiss the action.