The doctrine bars recovery of payments that are made voluntarily and with full knowledge of the facts, and in the absence of fraud or mistake of material fact or law. There is a presumption that payments are voluntary, and a protest of payment must be memorialized in a contemporaneous writing.
ECI Fin. Corp. v. Resurrection Temple of Our Lord, Inc., NY Slip Op 00649 (2d Dep't February 8, 2023)
