The existence of a valid and enforceable written contract governing a particular subject matter ordinarily precludes recovery in quasi contract for events arising out of the same subject matter. It makes no difference that the defendants are not parties to the contracts governing the dispute, as a nonsignatory to a contract cannot be held liable where there is an express contract covering the same subject matter.
Iberdrola Energy Projects v. MUFG Union Bank, N.A., NY Slip Op 03841 (1st Dep't July 13, 2023)
