Meyer v. Seidel, No. 21-2221 (2d Cir. 2023)
Annotate this CaseThe United States Court of Appeals for the Second Circuit considered an appeal from a judgment of the United States District Court for the Southern District of New York, which dismissed a plaintiff's 2019 complaint against art dealers for fraud, negligent misrepresentation, breach of warranty, and rescission in connection with his 2001 purchase of an allegedly forged painting. The district court dismissed the plaintiff's claims as time-barred and ruled that the plaintiff's fraud claim could not be granted relief. The plaintiff appealed, arguing that the district court erred in concluding that he was on inquiry notice of the alleged fraud before bringing the suit. The appellate court agreed with the district court that claims for breach of warranty, negligent misrepresentation, and rescission were time-barred under New York law. However, the court concluded that the district court erred in ruling that the fraud claims were time-barred and in denying the plaintiff's request for leave to amend his complaint. The case was affirmed in part, vacated in part, and remanded for further proceedings.
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