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Keywords

contractbreach of contractjurisdictionwrit of mandamusequitable relief
contractbreach of contractjurisdictionwrit of mandamusequitable relief

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Piraino, Matter of

Facts

On September 7, 2022, claimant purchased a Triple Red 777 scratch-off lottery ticket and discovered he had won a jackpot of either $3,000,000 in installments or a lump sum of $2,380,000. After submitting the winning ticket and claim form to the State Gaming Commission, claimant faced delays in payment. Despite submitting additional paperwork and threatening legal action, he did not receive payment, prompting him to file a claim on October 24, 2022. The Division eventually paid him on November 2, 2022, but the court dismissed his claim for lack of jurisdiction.

On September 7, 2022, claimant walked into Kiefer's Cigar Store at 409 Tulip Street in the Village of Liverpool, Onondaga County and purchased a Triple Red 777 scratch-off lottery ticket for $10. He scratched off the ticket and discovered that he had hit the jackpot, entitling him to a prize of either $3,000,000 to be paid in annual installments of $150,000 for 20 years or a lump sum payment of $2,380,000. The following day, claimant began the process of claiming that prize by submitting the winning ticket and a claim form to the State Gaming Commission, which operates the Division of the Lottery (hereinafter the Division). Claimant submitted further paperwork at the Division's request on September 16, 2022, electing to receive the jackpot as a lump sum payment [***2] of $2,380,000 and authorizing the Division to electronically deposit that amount in his checking account.

Issue

Whether the Court of Claims had subject matter jurisdiction to hear a claim for breach of contract regarding lottery winnings and whether a writ of mandamus was the appropriate remedy.

Whether the Court of Claims had subject matter jurisdiction to hear a claim for breach of contract regarding lottery winnings and whether a writ of mandamus was the appropriate remedy.

Rule

A CPLR article 78 claim cannot be pursued in the Court of Claims, and the essential nature of the claim must be assessed to determine if it seeks monetary recovery or if the monetary relief is incidental to the primary claim.

A CPLR article 78 claim cannot be pursued in the Court of Claims and, to assess whether it has subject matter jurisdiction to hear a claim, "the [***3] threshold question . . . is whether the essential nature of the claim is to recover money, or whether the monetary relief is incidental to the primary claim".

Analysis

The court determined that although claimant styled his claim as one for breach of contract, his actual goal was to compel the Division to approve his claim form and pay the lottery winnings. The court noted that the claimant's counsel explicitly indicated the delay in payment was an illegal abuse of the Division's obligations, and thus the claim was properly categorized as a CPLR article 78 proceeding, which cannot be heard in the Court of Claims.

Here, although claimant styled his claim as one for breach of contract and sought money, it is apparent from the record that his actual goal was to compel the Division to approve his claim form and pay over the lottery winnings to which he was entitled. Indeed, claimant's counsel made clear in his October 19, 2022 email to Division officials and others that he viewed the delay in processing the claim form and making payment to be "an illegal ABUSE of [the Division's] obligations" that had been done "[w]ithout reason or justification" and that [***4] claimant would "seek[ ] a [w]rit of [m]andamus" if the Division did not act.

Conclusion

The court affirmed the dismissal of the claim, concluding that the Court of Claims lacked jurisdiction to grant equitable relief and that the claimant's monetary recovery was incidental to the primary claim.

We affirm. The Court of Claims lacks jurisdiction to grant [*1458] equitable relief and, to assess whether it has subject matter jurisdiction to hear a claim, "the [***3] threshold question . . . is whether the essential nature of the claim is to recover money, or whether the monetary relief is incidental to the primary claim".

Who won?

The State prevailed in the case because the court found that the claimant's action was improperly filed in the Court of Claims, which lacks jurisdiction over CPLR article 78 claims.

The State prevailed in the case because the court found that the claimant's action was improperly filed in the Court of Claims, which lacks jurisdiction over CPLR article 78 claims.

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