New York Laws
Title 3 - Certain Prohibited Contracts and Provisions of Contracts
5-327 - Consumers' Right to Recover Attorney's Fees in Actions Arising Out of Consumer Contracts.

(a) "Consumer contract" means a written agreement entered into between
a creditor, seller or lessor as one party with a natural person who is
the debtor, buyer or lessee as the second party, and the money, other
personal property or services which are the subject of the transaction
are primarily for personal, family or household purposes;
(b) "Creditor" means a person who regularly extends, or arranges for
the extension of, credit which is payable by agreement in more than four
installments or for which the payment of a finance charge is or may be
required;
(c) "Seller" means a person who sells or provides or agrees to sell or
provide the subject of a consumer transaction.
(d) "Lessor" means a person who regularly leases, or arranges for the
lease of, personal property which is the subject of a consumer contract.
2. Whenever a consumer contract provides that the creditor, seller or
lessor may recover attorney's fees and expenses incurred as the result
of a breach of any contractual obligation by the debtor, buyer or
lessee, it shall be implied that the creditor, seller or lessor shall
pay the attorney's fees and expenses of the debtor, buyer or lessee
incurred as the result of a breach of any contractual obligation by the
creditor, seller or lessor, or in the successful defense of any action
arising out of the contract commenced by the creditor, seller or lessor.
Any limitations on attorney's fees recoverable by the creditor, seller
or lessor shall also be applicable to attorney's fees recoverable by the
debtor, buyer or lessee under this section. Any waiver of this section
shall be void as against public policy.