is a landmark case of the Supreme Court of Canada that supports recent reforms to Canadian civil procedure in the area of granting summary judgment in civil cases. Background Civil justice reform Summary judgment procedures were first introduced in Canadian courts in the 1980s. Ontario, after a study on the issues of access to justice, reformed its rules in 2010 to extend the powers of motion judges and masters for ordering summary judgment. This followed the introduction of similar measures in Alberta and British Columbia, all of which have been inspired by the reforms introduced in the English Civil Procedure Rules and the US Federal Rules of Civil Procedure. The present case A group of American investors (the "Mauldin Group") placed their money in the hands of Tropos Capital Inc., a company incorporated in Barbados that traded in bonds and debt instruments. At the end of June 2001, the group wired US$1.2 million to Cassels Brock (a Canadian law firm), which was pooled with other funds and transferred to Tropos. A few months later, Tropos forwarded more than US$10 million to an offshore bank, and the money disappeared. Hryniak (the principal of Tropos) claimed that at this point, Tropos's funds, including the funds contributed by the Mauldin Group, were stolen. The Mauldin Group joined with Bruno Appliance and Furniture, Inc. (another affected investor) in an action for civil fraud against Hryniak, Cassels Brock and Peebles, a former managing partner of the latter. The group brought motions for summary judgment, which were heard together. The courts below At the Ontario Superior Court of Justice, the motion judge held that: a trial was not required against Hryniak summary judgment should be dismissed against Peebles, as there were factual issues that called for a trial to be held summary judgment should also be dismissed against Cassels Brock, as the claim was based on the firm's vicarious liability with respect to Peebles Accordingly, he ordered Hryniak to pay more than US$2 million in damages. The ruling marked the first successful use of summary judgment in an Ontario fraud case. The Ontario Court of Appeal heard the appeal together with others, in its first consideration of the 2010 changes made to summary judgment procedures in Ontario. While concluding that this specific case was not an appropriate candidate for summary judgment, the Court of Appeal was satisfied that the record supported the finding that Hryniak had