Trump v. Trump
Docket Index No. 453299/21|Appeal No. 6199|Case No. 2025-03886|
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- Filed
- Jurisdiction
- New York
- Court
- Appellate Division of the Supreme Court of the State of New York
- Type
- Opinion
- Case type
- Civil
- Disposition
- Reversed
- Citation
- 2026 NY Slip Op 02735
- Docket numbers
- Index No453299/21Appeal No6199Case No2025-03886
Appeal from an order denying defendant's motion to compel discovery in a breach of settlement agreement action
Summary
The Appellate Division, First Department reversed Supreme Court's May 21, 2025 order and granted Mary Trump's motion to compel discovery from Donald Trump in a breach-of-settlement-agreement case. Mary Trump asserted an affirmative defense of fraudulent inducement based on alleged false asset valuations in a 2001 settlement agreement. The court held that because the requested materials relate to that affirmative defense they are discoverable under CPLR 3101(a), which requires liberal disclosure of matter material and necessary to prepare for trial. The case was remanded for further proceedings consistent with the decision.
Issues Decided
- Whether defendant is entitled to discovery of materials related to valuations in a 2001 settlement agreement to support her affirmative defense of fraudulent inducement
- Whether plaintiff bears the burden to show that discovery related to an unchallenged affirmative defense is improper
Court's Reasoning
CPLR 3101(a) requires liberal disclosure of all matter material and necessary to the prosecution or defense of an action. Because defendant's requested materials bear on her asserted affirmative defense of fraudulent inducement and will assist preparation for trial, the materials are discoverable. The court also noted that plaintiff must establish that such discovery is improper; Supreme Court abused its discretion by denying the motion without that showing.
Authorities Cited
- CPLR 3101(a)
- Allen v Crowell-Collier Publ. Co.21 NY2d 403 (1968)
- Roman Catholic Church of Good Shepherd v Tempco Sys.202 AD2d 257 (1st Dept 1994)
- Rivera v NYP Holdings Inc.63 AD3d 469 (1st Dept 2009)
Parties
- Plaintiff
- Donald J. Trump
- Defendant
- Mary L. Trump
- Defendant
- The New York Times Company Doing Business as The New York Times
- Appellant
- Mary L. Trump
- Respondent
- Donald J. Trump
- Judge
- Robert R. Reed
- Judge
- Webber, J.P.
- Judge
- González
- Judge
- Mendez
- Judge
- O'neill Levy
- Judge
- Hagler
Key Dates
- Decision date
- 2026-04-30
- Supreme Court order entered
- 2025-05-21
What You Should Do Next
- 1
Proceed with discovery in Supreme Court
On remand, the parties should address the scope, timing, and format of the production of materials related to the 2001 valuations; follow any court-ordered discovery schedule.
- 2
Prepare motions to resolve disputes
If plaintiff resists production, defendant may move to compel specific documents and the court may resolve privilege or relevance disputes.
- 3
Consider appellate options
If either party disagrees with the Appellate Division's ruling, they should evaluate seeking leave to appeal to the New York Court of Appeals and consult counsel about deadlines.
Frequently Asked Questions
- What did the court decide?
- The appellate court reversed the lower court and ordered that Mary Trump be allowed to obtain discovery related to alleged false valuations in the 2001 settlement agreement to support her fraudulent inducement defense.
- Who is affected by this decision?
- Mary Trump (the defendant/appellant) benefits because she can seek the requested materials; Donald Trump (the plaintiff/respondent) will have to produce or justify withholding those materials.
- What happens next in the case?
- The case is remanded to Supreme Court for further proceedings consistent with the order, including resolving the scope and production of the requested discovery.
- On what legal grounds did the court grant discovery?
- The court relied on CPLR 3101(a) and precedents requiring liberal disclosure of material and necessary information bearing on the controversy, especially when it supports an asserted affirmative defense.
- Can this decision be appealed further?
- Yes; the party dissatisfied with the Appellate Division's decision may seek leave to appeal to the Court of Appeals, subject to the applicable rules and deadlines.
The above suggestions and answers are AI-generated for informational purposes only. They may contain errors. NoticeRegistry assumes no responsibility for their accuracy. Consult a qualified attorney before relying on them.
Full Filing Text
Trump v Trump - 2026 NY Slip Op 02735 Trump v Trump 2026 NY Slip Op 02735 April 30, 2026 Appellate Division, First Department Donald J. Trump, Plaintiff-Respondent, v Mary L. Trump, Defendant-Appellant. The New York Times Company Doing Busniess as The New York Times et al., Defendants. Decided and Entered: April 30, 2026 Index No. 453299/21|Appeal No. 6199|Case No. 2025-03886| Before: Webber, J.P., González, Mendez, O'neill Levy, Hagler, JJ. Gibson, Dunn & Crutcher LLP, New York (Lee R. Crain of counsel), for appellant. Madaio Eyet & Associates, New York (Michael T. Madaio of counsel), for respondent. Order, Supreme Court, New York County (Robert R. Reed, J.), entered May 21, 2025, which, to the extent appealed from, denied defendant Mary Trump's motion to compel certain discovery, unanimously reversed, on the law, without costs, the motion granted and the matter remanded for further proceedings. Plaintiff commenced this action against defendant for breach of the confidentiality provisions of a 2001 settlement agreement. In her answer, defendant asserted the affirmative defense of fraudulent inducement. Specifically, she alleged that she relied upon the valuation of certain assets set forth in the parties' 2001 settlement agreement, and that those valuations were false. Defendant's motion to compel seeks discovery of materials related to the valuations provided in the settlement agreement. Plaintiff bears the burden of establishing that the discovery sought by defendant, which relates to an affirmative defense of fraudulent inducement that plaintiff has not otherwise challenged in this action, is improper ( see Roman Catholic Church of Good Shepherd v Tempco Sys. , 202 AD2d 257, 258 [1st Dept 1994]). Supreme Court improvidently exercised its discretion in denying defendant's motion. CPLR 3101(a) directs "full disclosure of all matter material and necessary in the prosecution or defense of an action," and is to be "interpreted liberally to require disclosure, upon request, of any facts bearing on the controversy which will assist preparation for trial by sharpening issues and reducing delay and prolixity" ( Allen v Crowell-Collier Publ. Co. , 21 NY2d 403, 406 [1968]). These principles entitle defendant to the requested discovery material to establish her affirmative defense ( see Rivera v NYP Holdings Inc. , 63 AD3d 469, 469 [1st Dept 2009]; Roman Catholic Church of Good Shepherd , 202 AD2d at 257-258). THIS CONSTITUTES THE DECISION AND ORDER OF THE SUPREME COURT, APPELLATE DIVISION, FIRST DEPARTMENT. ENTERED: April 30, 2026