David Falk v. Meyer F. Goodman

Summary

The New York Court of Appeals reversed the Appellate Division and denied the summary judgment motion, holding that genuine issues of fraud in the performance of a valid contract preclude summary judgment. The court explained that the parol‑evidence rule cannot be used to grant summary judgment on such a defense and that an escrow agent may assert defenses in an interpleader context. Justice Desmond dissented, arguing that the plaintiffs were entitled to summary judgment. The case was remanded for further proceedings.