Jadidian v. Goldstein: Pleading Fraud to Take Advantage of a Longer Fiduciary-Duty Limitations Period

This blog often addresses the statute of limitations for breach of fiduciary duty claims (see here and here, for example). Which limitations period applies to a breach of fiduciary duty claim is a frequently recurring issue. This is because there is no single statute of limitations for fiduciary-duty claims, but three distinct possibilities:

1. A six-year period for claims seeking equitable relief (e.g., a permanent injunction or declaratory judgment);
   
2. A three-year period for claims seeking purely monetary relief; and
   
3. A six-year period where allegations of fraud are essential to the breach of fiduciary duty claim.

Jadidian v. Goldstein, 210 A.D.3d 969 (2d Dep’t 2022), a recent decision of the Appellate Division, Second Department, provides useful guidance on how to maximize the chance that a fiduciary-duty claim based on fraud (the third category above) survives a motion to dismiss.

Read the full blog here.