Canfield Funding, LLC v. Focalpointe Group, LLC

2025 NY Slip Op 04374
CourtAppellate Division of the Supreme Court of the State of New York
DecidedJuly 25, 2025
Docket517 CA 24-00417
StatusPublished

This text of 2025 NY Slip Op 04374 (Canfield Funding, LLC v. Focalpointe Group, LLC) is published on Counsel Stack Legal Research, covering Appellate Division of the Supreme Court of the State of New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Canfield Funding, LLC v. Focalpointe Group, LLC, 2025 NY Slip Op 04374 (N.Y. Ct. App. 2025).

Opinion

Canfield Funding, LLC v Focalpointe Group, LLC (2025 NY Slip Op 04374)

Canfield Funding, LLC v Focalpointe Group, LLC
2025 NY Slip Op 04374
Decided on July 25, 2025
Appellate Division, Fourth Department
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
This opinion is uncorrected and subject to revision before publication in the Official Reports.


Decided on July 25, 2025 SUPREME COURT OF THE STATE OF NEW YORK Appellate Division, Fourth Judicial Department
PRESENT: WHALEN, P.J., BANNISTER, OGDEN, GREENWOOD, AND KEANE, JJ.

517 CA 24-00417

[*1]CANFIELD FUNDING, LLC, PLAINTIFF-RESPONDENT-APPELLANT,

v

FOCALPOINTE GROUP, LLC, MICHAEL MANN, DEFENDANTS, UNITEDHEALTH GROUP INCORPORATED, OPTUM, INC., AND OPTUMINSIGHT, INC., DEFENDANTS-APPELLANTS-RESPONDENTS.


CONNORS LLP, BUFFALO (RANDALL D. WHITE OF COUNSEL), FOR DEFENDANTS-APPELLANTS-RESPONDENTS.

MAGAVERN MAGAVERN GRIMM LLP, BUFFALO (EDWARD J. MARKARIAN OF COUNSEL), FOR PLAINTIFF-RESPONDENT-APPELLANT.



Appeal and cross-appeal from an order of the Supreme Court, Erie County (Emilio Colaiacovo, J.), entered January 23, 2024. The order, among other things, denied in part the motion of defendants UnitedHealth Group Incorporated, Optum, Inc. and Optuminsight, Inc. to dismiss the complaint against them.

It is hereby ORDERED that the order so appealed from is unanimously modified on the law by granting that part of the motion seeking to dismiss the fraudulent misrepresentation cause of action to the extent that it is based on fraudulent acts occurring prior to August 15, 2016, and as modified the order is affirmed without costs.

Memorandum: Plaintiff commenced this action seeking to recover damages it sustained in a fraudulent scheme perpetrated by defendant Focalpointe Group, LLC (Focalpointe) and its principal, defendant Michael Mann. Plaintiff also named as defendants UnitedHealth Group Incorporated, Optum, Inc., and Optuminsight, Inc. (UHG/Optum defendants), whose employees allegedly assisted Mann in his fraudulent scheme. As against UHG/Optum defendants, plaintiff asserted causes of action for fraudulent misrepresentation, aiding and abetting fraud, and negligent supervision. UHG/Optum defendants moved to dismiss the complaint against them pursuant to, inter alia, CPLR 3211 (a) (5), (7), and (8). Plaintiff did not contest the dismissal of the aiding and abetting fraud cause of action, and Supreme Court granted the motion insofar as it sought dismissal of that cause of action as well as the cause of action for negligent supervision against UHG/Optum defendants, but otherwise denied the motion. UHG/Optum defendants appeal, and plaintiff cross-appeals.

Contrary to UHG/Optum defendants' contention on their appeal, the court properly denied that part of the motion seeking to dismiss the fraudulent misrepresentation cause of action against them for failure to state a cause of action. On a motion to dismiss pursuant to CPLR 3211 (a) (7) for failure to state a cause of action, we must "accept the facts as alleged in the complaint as true, accord [the]

plaintiff[ ] the benefit of every possible favorable inference, and determine only whether the facts as alleged fit within any cognizable legal theory" (Leon v Martinez, 84 NY2d 83, 87-88 [1994]; see AG Capital Funding Partners, L.P. v State St. Bank & Trust Co., 5 NY3d 582, 591 [2005]). "Whether a plaintiff can ultimately establish [their] allegations is not part of the calculus in determining a motion to dismiss" (EBC I, Inc. v Goldman, Sachs & Co., 5 NY3d 11, 19 [2005]; see Cortlandt St. Recovery Corp. v Bonderman, 31 NY3d 30, 38 [2018]).

"Generally, in a claim for fraudulent misrepresentation, a plaintiff must allege a misrepresentation or a material omission of fact which was false and known to be false by defendant, made for the purpose of inducing the other party to rely upon it, justifiable reliance of [*2]the other party on the misrepresentation or material omission, and injury" (Mandarin Trading Ltd. v Wildenstein, 16 NY3d 173, 178 [2011] [internal quotation marks omitted]).

Here, plaintiff alleges that it provides accounts receivable factoring to businesses whereby it purchases accounts receivable from clients at a discount, the invoices are assigned to plaintiff, and plaintiff then collects those receivables from the third-party debtors. Plaintiff entered an agreement with Focalpointe in October 2013 for plaintiff to purchase accounts receivable from Focalpointe for alleged information technology (IT) services it provided to UHG/Optum defendants. Focalpointe would generate invoices for those services it provided and give those invoices to plaintiff for factoring. Plaintiff verified with UHG/Optum defendants that those invoices from Focalpointe were due and payable. But as it turned out, between November 2013 and September 2019, UHG/Optum defendants did not have a legitimate business relationship with Focalpointe and the invoices were a sham. Mann created accounts to make it appear as if UHG/Optum defendants were making payments on the fraudulent invoices, and he obtained financing from another factoring company to build a pyramid scheme.

Plaintiff alleges that it relied on representations made by UHG/Optum defendants through four of their employees. Plaintiff's primary contact at UHG/Optum defendants was employee number one, a "Director" whose responsibilities included "staffing" and "financial analysis." Employee number one represented that he was responsible for verifying Focalpointe's invoices and verified them on hundreds of occasions over six years. Plaintiff alleges that it also communicated with three other employees of UHG/Optum defendants. In October 2014, employee number two, a "Director" at the New York office of Optum, Inc. and Optuminsight, Inc., confirmed that UHG/Optum defendants' ledger showed open Focalpointe invoices in the same amount as shown by plaintiff and confirmed that plaintiff was noted to be the proper assignee of Focalpointe's open invoices with UHG/Optum defendants. In February 2015, employee number three, a "Vice President" with responsibilities including "vendor management" and "IT delivery," confirmed that Focalpointe had an account balance with UHG/Optum defendants in the amount of $3.4 million and further noted that employee number one was the appropriate contact at UHG/Optum defendants with respect to financial matters. In July 2015, employee number four confirmed that Focalpointe had an account balance with UHG/Optum defendants in the amount of $3.2 million and purported to "approve" additional Focalpointe invoices.

UHG/Optum defendants contend that plaintiff's allegations are insufficient to establish that the four employees had apparent authority to bind UHG/Optum defendants. We disagree. "[A] principal may be held liable in tort for the misuse by its agent of [their] apparent authority to defraud a third party who reasonably relies on the appearance of authority, even if the agent commits the fraud solely for [their] personal benefit, and to the detriment of the principal" (Parlato v Equitable Life Assur. Socy. of U.S., 299 AD2d 108, 113 [1st Dept 2002], lv denied 99 NY2d 508 [2003]; see American Socy. of Mech. Engrs., Inc. v Hydrolevel Corp., 456 US 556, 566 [1982], reh denied 458 US 1116 [1982]; News Am. Mktg., Inc. v Lepage Bakeries, Inc., 16 AD3d 146, 148 [1st Dept 2005]).

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2025 NY Slip Op 04374, Counsel Stack Legal Research, https://law.counselstack.com/opinion/canfield-funding-llc-v-focalpointe-group-llc-nyappdiv-2025.