Extortion with an E.

There is no private cause of action for extortion or attempted extortion, according to the First Department, in Minnelli v. Soumayah, which was decided on June 28, 2007. In dismissing that cause of action, in which plaintiff had alleged that defendant had compelled her to deliver money to him by threatening physical harm to plaintiff and her employees, the court observed that "extortionate behavior, coercion and duress may be elements of a cause of action for tortious interference with contract or unjust enrichment." The court also said that a mere threat, without something forcing the other party to give in to a further demand, is insufficient to make out a cause of action sounding in economic duress.