Merger clauses and the duplication of claims doctrine often operate to limit the availability of fraudulent inducement claims alongside breach of contract claims.

Under New York law, fraud claims are not duplicative of breach of contract claims when they are based on misrepresentations of present fact collateral to the contract, even if they seek the same damages. Applying that rule, the Appellate Division, First Department held in Metropolitan Partners Group Admin., LLC v. Nerney, 2026 N.Y. Slip Op. 02340 (1st Dept. Apr. 16, 2026), that plaintiff adequately pleaded both fraud and breach of contract claims ...