R 3015.Particularity as to specific matters.
Article 30. Remedies and Pleading · Last amended 2019 · Last verified July 21, 2026
Full Text of CPLR 3015
Plain-English Summary
CPLR 3015 gathers a handful of pleading problems that come up often enough to deserve their own rule, each one either loosening or tightening the general particularity standard of CPLR 3013 for a specific recurring situation. Most of the subdivisions trace back to older, subject-specific pleading rules that predate the CPLR.
Under subdivision (a), a plaintiff doesn't have to plead performance of every condition precedent in a contract — a general allegation of performance is enough. But a defendant who wants to contest that performance must deny it specifically and with particularity, and that specific denial then caps what the defendant can contest at trial: only the conditions the denial identified. Subdivision (b) requires a complaint against a corporate party to say so, and to name the state, country, or government of incorporation if known. Subdivision (c) lets a party plead a prior judgment or determination without pleading facts showing the deciding tribunal had jurisdiction to render it.
Subdivision (d) treats a signature on a negotiable instrument as admitted unless a party specifically denies it — a rule that streamlines suits on notes and checks by taking authenticity off the table absent a real dispute. Subdivision (e) requires a plaintiff suing a consumer over a business that needs a local consumer-affairs license — in New York City, Suffolk, Rockland, Putnam, Westchester, or Nassau County — to allege that it held that license at the time of the services, along with the license number and issuing agency; skipping that allegation opens the door to a motion to dismiss under CPLR 3211(a)(7), a point regularly raised in debt-collection and home-improvement litigation. A related carve-out in CPLR 3012-b turns off subdivision (d)'s automatic-admission rule for a self-represented defendant in a residential foreclosure case, and CPLR 3016(j) layers still more detailed disclosure requirements onto consumer-credit assignment claims.
Frequently Asked Questions
Do I have to allege that I performed every condition in a contract before suing on it?
No. CPLR 3015(a) says a general allegation of performance is enough; the burden shifts to the defendant, who must deny nonperformance specifically and with particularity.
How do I deny that a condition precedent was met?
The denial has to be specific and particular, identifying which conditions are disputed — CPLR 3015(a) then limits the party relying on performance to proving only the conditions the denial specified.
Do I need to state where a corporate defendant was incorporated?
The complaint must state that the party is a corporation, and, where the plaintiff knows it, the state, country, or government under whose laws it was formed, under CPLR 3015(b).
Can I plead a prior judgment without alleging the court had jurisdiction to issue it?
Yes. CPLR 3015(c) allows a judgment, decision, or other determination to be pleaded without stating facts showing the tribunal's jurisdiction to render it.
Is a signature on a promissory note automatically admitted in a New York lawsuit?
Yes, unless specifically denied. CPLR 3015(d) treats each signature on a negotiable instrument as admitted absent a specific denial in the pleadings.
What is CPLR 3015(e) and when must a plaintiff plead a consumer-affairs license?
It applies when a plaintiff's claim against a consumer arises from a business required to be licensed by a local consumer-affairs department listed in the statute, requiring the complaint to allege the license, its number, and the issuing agency.
What happens if a debt collector suing a consumer skips the licensing allegation required by CPLR 3015(e)?
The omission lets the defendant move to dismiss under CPLR 3211(a)(7) for failing to plead a required element of the cause of action.
Advisory Committee Notes
Many special pleading rules similar to those in this rule and the following rule are found in the various jurisdictions. See the collection in Brown, Digest of Procedural Statutes and Court Rules 19 et seq. (1954). Further examples may be found in the procedural codes of particular courts.
Subd. (a) of this rule is based upon RCP 92. A statement confirming that the burden of proof remains with the plaintiff, as in New Jersey rule 4:9-2 and as indicated by RCP 92, has been considered inappropriate in this provision. The subdivision adopts the English rule implying such performance. See 12 NY Jud Council Rep 365, 368, 370 (1946). A general allegation of performance of conditions precedent is useless, adding nothing to the information a defendant gains from reading the complaint. The last sentence of the subdivision derives from the last sentence of former RCP 92.
Subd. (b) of this rule is based upon RCP 93(1). No change in meaning is intended.
Subd. (c) of this rule expands RCP 95 to include other tribunals in the manner of Federal rule 9(e).
Subd. (d) of this rule is based upon Federal rule 9(g).
Amendment History
Formerly § 3015, add, L 1962, ch 308; renumbered Rule 3015, L 1962, ch 318, § 13, eff Sept 1, 1963; L 1983, ch 817, § 1; L 1984, ch 243, § 1; L 1985, ch 26, § 1; L 1986, ch 26, § 1; L 1990, ch 654, § 1; L 1996, ch 465, § 1, eff Aug 8, 1996; L 2012, ch 458, § 1, eff Oct 3, 2012; L 2013, ch 21, § 1, eff May 2, 2013; L 2019, ch 693, § 1, effective December 20, 2019.