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Thompson & Skrabanek Secures Extremely Rare Reversal of Summary Judgment through a "Motion for Reconsideration" in Federal Breach of Contract Case

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Thompson & Skrabanek is proud to announce a remarkable legal feat in the case of Woodside Credit, LLC v. Deloy, which is presently being litigated in the Eastern District of New York. The matter is a breach of contract dispute centered on a financing agreement for a Rolls Royce. Representing the defendant, Justin Lee Deloy, the Firm successfully convinced the court to reconsider and overturn its prior ruling, which had initially granted summary judgment in favor of the plaintiff. This would have deprived Mr. Deloy of his right to a trial to contest the claims against him.


The case involves allegations by Woodside Credit that Mr. Deloy had authorized an agent to enter into a financing agreement on his behalf. In its original decision, the court concluded that the plaintiff was entitled to judgment as a matter of law, citing the existence of an agency relationship between Mr. Deloy and his associate. However, Partner J.R. Skrabanek and Associate Mastewal Terefe successfully demonstrated that the court had overlooked binding legal precedent and significant factual disputes in its initial decision and that the decision was in error. These issues included whether the associate in question acted within the scope of his authority when purchasing a vehicle in Mr. Deloy’s name. Mr. Deloy steadfastly denies the allegations that he was aware a luxury vehicle had been purchased with his credentials.


In its reconsideration ruling, issued on December 2, 2024, the court recognized that genuine disputes of material fact exist, specifically regarding whether Mr. Deloy had expressly or implicitly authorized the associate to sign the financing agreement on his behalf. Additionally, the court found that the question of "apparent authority"—whether the associate appeared to third parties to have the authority to act on Mr. Deloy’s behalf—also required a factual determination that precluded summary judgment.


This outcome is a testament to Thompson & Skrabanek’s meticulous attention to detail and deep understanding of agency law. Motions for reconsideration are notoriously difficult to win in federal court, making this result particularly noteworthy. By some estimates, as few as one in twenty such motions are granted in the federal judicial system. We are pleased that the court recognized the importance of these unresolved factual issues and granted our client the opportunity to have his day in court.


This ruling not only reverses the earlier summary judgment but also highlights Thompson & Skrabanek’s dedication to securing the best possible outcomes for its clients, even in challenging and complex cases. The Firm’s success in this matter underscores its reputation for excellence in advocacy and its ability to navigate nuanced legal issues with precision and skill.


A copy of the court's decision is available immediately below:



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