Donald J. Trump v. Mary L. Trump
Attorneys and Parties
Brief Summary
Civil litigation discovery in a contract dispute involving a breach of confidentiality claim and a fraudulent inducement defense.
The lower court denied Mary Trump's motion to compel discovery of materials concerning asset valuations referenced in the parties' 2001 settlement agreement.
The Appellate Division reversed the portion of the order denying Mary Trump's motion to compel and remanded for further proceedings.
The requested materials were relevant to Mary Trump's affirmative defense of fraudulent inducement, and under CPLR 3101(a) [requires full disclosure of all matter material and necessary in the prosecution or defense of an action], discovery is to be interpreted liberally. The plaintiff did not meet his burden to show that the discovery request was improper.
Background
Donald J. Trump sued Mary L. Trump for allegedly breaching confidentiality provisions in a 2001 settlement agreement. In response, Mary Trump asserted an affirmative defense of fraudulent inducement, alleging that she relied on asset valuations stated in the settlement agreement and that those valuations were false. She then sought discovery of materials related to those valuations to support that defense.
Lower Court Decision
Supreme Court, New York County denied Mary Trump's motion to compel the requested discovery materials related to the settlement valuations.
Appellate Division Reversal
The Appellate Division unanimously reversed that ruling, granted the motion to compel, and remanded the matter for further proceedings. The court held that the sought-after valuation materials were material and necessary to Mary Trump's fraudulent inducement defense and therefore discoverable.
Legal Significance
The decision reinforces New York's liberal discovery standard and confirms that when a defendant pleads fraudulent inducement as an affirmative defense, discovery relevant to that defense should generally be allowed unless the opposing party shows it is improper. It also places the burden on the plaintiff to justify withholding such discovery when the defense has not otherwise been challenged.
A party asserting fraudulent inducement may obtain broad discovery into the facts underlying the alleged misrepresentation, especially where those facts bear directly on whether the party was induced to enter the agreement.