Brief Fact Summary. Metropolitan Steel Industries, Inc. (Metropolitan) sought to collect money owed to it under a contract that was assigned to Presbyterian Hospital (Presbyterian Hospital) in the City of New York.
Synopsis of Rule of Law. An assignment of a contract is an assignment of future rights under the agreement, not an assignment of duties and liabilities incurred prior to assignment.
Issue. Did the assignment of the subcontract to Presbyterian Hospital obligate the hospital to pay for work already performed?
Held. No. An assignment of a contract is an assignment of future rights under the agreement, not of duties and liabilities incurred prior to assignment. Here, the assignment contains no language by which Presbyterian Hospital assumed any of Walsh’s liabilities for work performed prior to the assignment. Dismissal of the breach of contract claim by Metropolitan against Presbyterian Hospital was appropriate.
Discussion. An assignment only transfers future rights, not past obligations.