Koch v. Christie's Int'l PLC
United States Court of Appeals for the Second Circuit
May 2, 2012, Argued; October 4, 2012, Decided
Docket No. 11-1522-cv
[*144] John G. Koeltl, [**2] District Judge:
For wine, timing is critical. The same is true for causes of action.
This case requires us to clarify the operation of "inquiry notice" in the context of a civil action pursuant to the Racketeer Influenced and Corrupt Organizations Act ("RICO"), 18 U.S.C. § 1961 et seq., and common law fraud claims under New York law. This analysis is necessary to determine whether the wine-related causes of action in this case were stale when brought. The claims relate to alleged fraud in inflating the value of bottles of wine by falsely attributing them to Thomas Jefferson's wine collection.
Plaintiff-appellant William I. Koch appeals from the judgment of the United States District Court for the Southern District of New York (Jones, J.) that dismissed his claims against Christie's International PLC; Christie, Mason & Woods, Ltd.; and Christie's Inc. (collectively, "Christie's") because they were time-barred. The District Court dismissed the claims pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure. Koch v. Christie's International PLC, 785 F. Supp. 2d 105 (S.D.N.Y. 2011).
The essence of Koch's allegations against Christie's is that Christie's promoted as authentic [**3] a cache of wine that was ostensibly bottled in the late eighteenth century and was linked to Thomas Jefferson. Koch alleges that these "Jefferson wines" were in fact counterfeit, and that Christie's knew or was reckless in not knowing of the wines' dubious authenticity. Koch purchased four bottles of the now discredited Jefferson wines from third-party dealers in November and December of 1988, allegedly relying on promotional representations made by Christie's. In January of 2008, Koch and Christie's agreed to toll the statute of limitations with respect to any claims against Christie's arising out of the Jefferson wine sales. Koch then filed this lawsuit in March 2010.
Koch argues that the District Court erred in describing and applying the legal standard with respect to the doctrine of inquiry notice, ] under which, in some circumstances, a court imputes to a plaintiff knowledge of facts sufficient to trigger the running of the statute of limitations where the plaintiff could have discovered those facts by a reasonably diligent investigation. Koch further argues that, in any event, the Supreme Court's decision in Merck & Co. v. Reynolds, 559 U.S. 633, 130 S. Ct. 1784, 176 L. Ed. 2d 582 (2010), changed the law with [**4] respect to what knowledge is required to trigger accrual in cases arising under RICO. Koch also argues that the District Court erred in dismissing his New York state law claims as time-barred because the standard for inquiry [*145] notice under New York law is different from the standard under federal law in RICO cases, and his claims should survive under the New York standard.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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699 F.3d 141 *; 2012 U.S. App. LEXIS 20758 **; 2012 WL 4677700
WILLIAM I. KOCH, Plaintiff-Appellant, -v.- CHRISTIE'S INTERNATIONAL PLC, A U.K. PUBLIC LIMITED COMPANY, CHRISTIE, MASON & WOODS, LIMITED, A U.K. PRIVATE LIMITED COMPANY, CHRISTIE'S INCORPORATED, A NEW YORK CORPORATION, Defendants-Appellees.
Prior History: [**1] This is an appeal from the judgment of the United States District Court for the Southern District of New York (Jones, J.) dismissing the civil RICO conspiracy and common law fraud claims of plaintiff-appellant William I. Koch against the defendants after determining that the statute of limitations for those claims had expired. The claims relate to alleged fraud in falsely attributing bottles of wine to Thomas Jefferson's collection. Because we find that Koch's claims were time-barred, we affirm the judgment of the District Court.
Koch v. Christie's Int'l PLC, 785 F. Supp. 2d 105, 2011 U.S. Dist. LEXIS 30682 (S.D.N.Y., 2011)Koch v. Rodenstock, 2010 U.S. Dist. LEXIS 49031 (S.D.N.Y., May 17, 2010)
wine, discovery, inquiry notice, bottle, statute of limitations, authenticity, accrual, probability, securities fraud, cases, alleges, imputed, limitations period, diligent, argues, reasonable diligence, discovery rule, two-year, trigger, accrue, two year, circumstances, time-barred, fraudulent, scienter, testing, storm, civil practice, fraud claim, constituting
Governments, Legislation, Statute of Limitations, Time Limitations, Civil Procedure, Defenses, Demurrers & Objections, Motions to Dismiss, Failure to State Claim, Appeals, Standards of Review, De Novo Review, Antitrust & Trade Law, Private Actions, Racketeer Influenced & Corrupt Organizations, Statute of Limitations, Courts, Judicial Precedent, Torts, Fraud & Misrepresentation, Actual Fraud, Defenses, Tolling, Discovery Rule, Equitable Estoppel, Abuse of Discretion, Tolling