Garceau Auto Sales, Inc. v. Scott A Carpenter, 13-01011

Garceau Auto seeks non-dischargeability under 11 U.S.C. § 523(a)(2)(A) for a $55,500 debt arising from a car purchase swap.
Carpenter moved for summary judgment based on bipolar disorder and alleged lack of mental capacity.
Undisputed facts include the 2012 vehicle swap, encumbrances, a dishonored $35,000 check, and Carpenter’s 2012 hospitalization.
Plaintiff argues mental state issues require trial; defendant argues lack of capacity negates elements of § 523(a)(2)(A).
Court finds the record not ripe for summary judgment and requires a supplemental brief addressing admissibility and issue preclusion before ruling.
Court identifies standards for summary judgment and the need to infer intent from totality of circumstances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
whether summary judgment is appropriate given the mental-state questions	Garceau argues facts show intentional misrepresentation	Carpenter asserts his bipolar disorder negates requisite intent	Not ripe; defer ruling pending supplementation
admissibility of medical reports as evidence of mental state	Reports should support facts about mental state	Reports are hearsay and admissibility not yet established	Objections meritorious; need admissible form or authentication; avoid summary judgment
whether New York judgment on mental disease/defect precludes relitigation of intent	Issue preclusion should bar relitigating intent	New argument raised late; may be considered with briefing	Court will consider but requires supplemental memorandum on issue preclusion

Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (genuine issue of material fact standard)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (U.S. 1986) (metaphysical doubt not enough to defeat summary judgment)
Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (burden on movant to show absence of material facts)
Vermont Teddy Bear Co. v. 1-800 Beargram Co., 373 F.3d 241 (2d Cir. 2004) (summary judgment standards; need for material facts)
Bronx Household of Faith v. Bd. of Educ. of City of New York, 492 F.3d 89 (2d Cir. 2007) (summary judgment standards; defer to record)