Franklin v. Hafftka
Cynthia Franklin, acting as special guardian for George S. Franklin, commenced an action against Michael and Yonat Hafftka, asserting claims including breach of contract and breach of fiduciary duty related to a joint residential property purchase and shared living arrangement. George S. Franklin, who had a history of mental illness, had entered into this agreement with the Hafftka defendants. The defendants sought to dismiss several causes of action as time-barred or for failing to state a cause of action, while the plaintiff cross-moved for leave to amend certain claims. The Supreme Court initially granted the dismissal of some causes of action and denied the cross-motion to amend. The Appellate Division modified this order, ruling that the defendants' motion to dismiss the first, third, fourth, fifth, and sixteenth causes of action, and parts of the sixth, seventh, and eighth causes of action as time-barred, should have been denied due to a question of fact regarding the application of fiduciary tolling or the "repudiation rule." The court affirmed the dismissal of the ninth cause of action for promissory estoppel and the eleventh for a purchase money resulting trust. Additionally, the Appellate Division granted the plaintiff leave to amend the fifth cause of action but denied amendment for the sixth and seventh causes of action.