The elements of a constructive trust are a fiduciary or confidential relationship, a promise, a transfer in reliance on that promise, and unjust enrichment. The transfer element extends to instances where funds, time and effort were contributed in reliance on a promise to share in the result. A party with no actual prior interest in the property must show that an equitable interest developed through the expenditure of money, labor, and time in the property.
Angel v. Struvolich, NY Slip Op 04149 (2d Dep't July 16, 2025)
