A New York appellate court has reinstated a lawsuit involving a breach of an oral escrow agreement. The decision, made on August 19, 2026, affects Scott Suprina, the plaintiff, and Fredric Goodman and his law firm, Marin Goodman, LLP, the defendants. This ruling is significant as it allows Suprina to pursue his claims against Goodman, which were previously dismissed by a lower court.
The case, titled Suprina v. Goodman, was filed under docket number 2025-01260. The Appellate Division of the Supreme Court of the State of New York decided to reverse the lower court's order, which had granted the defendants' motion to dismiss the complaint. This means that Suprina's allegations of breach of an oral escrow agreement and breach of fiduciary duty will now be heard in court.
The dispute began when Suprina alleged that Goodman and his law firm failed to uphold their obligations under an oral escrow agreement. An escrow agreement typically involves a third party holding funds or property until certain conditions are met. Suprina claimed that Goodman, who was acting as an escrow agent, did not fulfill his fiduciary duties, which led to financial losses for Suprina.
The case reached the appellate court after the Supreme Court in Nassau County, presided over by Justice Lisa A. Cairo, granted the defendants' motion to dismiss on November 12, 2024. The defendants argued that the evidence provided was sufficient to dismiss the case. However, Suprina appealed this decision, seeking to have the case reinstated.
The Appellate Division, which includes Judges Angela G. Iannacci, William G. Ford, Carl J. Landicino, and Susan Quirk, reviewed the arguments presented by both sides. In their ruling, the court stated, "The evidence submitted by the defendants did not demonstrate that a material fact as claimed by the plaintiff was not a fact at all and did not utterly refute the plaintiff's factual allegations." This indicates that the court found merit in Suprina's claims and believed that the case should proceed.
The court emphasized that a motion to dismiss should only be granted if the evidence presented by the defendants completely undermines the plaintiff's claims. The judges noted that the elements of an escrow agreement do not necessarily have to be in writing, which supports Suprina's position that an oral agreement could still be valid.
Furthermore, the court highlighted the importance of fiduciary duty in this case. An attorney holding funds in escrow has a responsibility to act in the best interest of all parties involved. The judges pointed out that an attorney can be held liable for breach of both the escrow agreement and fiduciary duty, even if there is no formal attorney-client relationship.
This ruling is significant for Suprina, as it allows him to continue seeking damages for the alleged breach of the escrow agreement and breach of fiduciary duty. The decision also reinforces the legal principle that oral escrow agreements can be enforceable and that attorneys have a fiduciary duty to their clients and others involved in the transaction.
Going forward, this case could set a precedent for similar disputes involving oral escrow agreements and the responsibilities of attorneys acting as escrow agents. It highlights the importance of clear communication and adherence to fiduciary duties in financial transactions.
As for what’s next, the case will return to the lower court for further proceedings. It remains to be seen how the defendants will respond to the reinstatement of the lawsuit. There is no indication in the court filing that the defendants plan to appeal this decision. Details were not available in the court filing regarding any related cases.