Civil conspiracy is not an independent tort in New York. However, the allegations of conspiracy are deemed part of a cause of action to which they are relevant, such as a claim for fraud, where liability may be premised on knowing participation in a scheme to defraud, even if that participation does not by itself suffice to constitute the fraud. The allegations of conspiracy enable a plaintiff to connect a defendant with the acts of co-conspirators where otherwise the defendant could not be implicated.
Errant Gene Thereapetics, LLC v. Sloan-Kettering Inst. for Cancer Research, NY Slip Op 05654 (1st Dep't July 23, 2019)
Here is the decision.
