In Moore Charitable Foundation v. PJT Partners, the Court of Appeals considered the scope of an employer's duty of supervision over its employee and whether a complaint sufficiently alleged that an employer was on notice of its employee's propensity to commit fraud before the employee caused injury to the plaintiff. In a majority decision written by Judge Anthony Cannataro and joined by Chief Judge Wilson and Judges Rivera, Troutman and Nancy E. Smith of the Fourth Department (sitting by designation), the court reversed the Appellate Division, First Department and held that the parties to whom employers owe a duty of supervision include more than just the employer's actual customers and that the plaintiffs adequately alleged a cause of action for negligent supervision and retention where the plaintiff was defrauded by an employee of the defendants while using his work email address and documents obtained in connection with his employment.