HomeMy WebLinkAbout02-3434 CivilROBERT H. LANDINO and
FRANCES B. LANDINO,
Plaintiffs
VS.
SON PAUCH, individually, and
SOPHANY RETH, individually,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
02-3434 CIVIL
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
PRELIMINARY OBJECTIONS OF DEFENDANT, SOPHANY RETH
BEFORE BAYLEY AND HESS, JJ.
OPINION AND ORDER
Robert H. Landino and Frances B. Landino (hereinafter "plaintiffs") contracted to
sell a parcel of real estate known as 776 Glen Arden Drive, Lewisberry, Fairview
Township, York County, Pennsylvania to Son Pauch and Sophany Reth (hereinafter
"defendants") for $360,000.00. An Agreement of Sale was executed by the parties on or
about July 29, 2001. Subsequent revisions to the Agreement were initialed by the parties
on July 30, 2001. Paragraph 3(D) of the Agreement obligated the defendants to pay a
deposit to the plaintiffs in the amount of $10,000.00 by August 6, 2001. The agreement
also contained a liquidated damages provision 27(C) which provided that in the event of a
default by the buyer the seller would be limited to retaining sums of money paid by
buyer, including any deposit monies, as liquidated damages. The contract provides,
specifically, that in the event of a default:
Seller is limited to retaining sums paid by Buyer, including
deposit moneys, as liquidated damages. If Seller elects to
retain all sums paid by Buyer, including deposit moneys, as
liquidated damages, Buyer and Seller will be released from
further liability or obligation and this Agreement will be VOID.
02-3434 CIVIL
A check in the amount of $10,000.00 was delivered on August 9, 2001 to the plaintiffs'
real estate agent. The check was returned "not paid" due to insufficient funds on August
15, 2001. Thereinafter, the defendants did not perform any obligations under the contract
and the plaintiffs later sold the property.
Plaintiffs filed a complaint to recover damages as the result of the breach of the
Agreement by the defendants. Defendant Sophany Reth has filed preliminary objections
to plaintiffs' complaint in the nature of a demurrer.
For the purposes of reviewing preliminary objections in the form of a demurrer,
"all well-pleaded material, factual averments and all inferences fairly deducible
therefrom" are presumed to be true. Tucker v. Philadelphia Daily News, 757 A.2d 938,
941-942 (Pa. Super. 2000). When presented with preliminary objections whose end
result would be the dismissal of a cause of action, a court should sustain the objections
only where "it is clear and free from doubt all the facts pleaded that the pleader will be
unable to prove facts legally sufficient to establish [its] right to relief." Bourke v.
Kazaras, 746 A.2d 642, 643 (Pa. Super. 1999). "The question presented by the demurrer
is whether, on the facts averred, the law says with certainty that no recovery is possible."
Bailey v. Storlazzi, 729 A.2d 1206, 1211 (Pa. Super. 1999).
Liquidated damages provisions are part of the standard form agreements of sale
prepared by the Pennsylvania Association of Realtors and used throughout the
Commonwealth of Pennsylvania. They are permitted and enforceable "provided that at
the time the parties enter into the contract, the sum agreed upon constitutes a reasonable
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expectation of loss rather than an unlawful penalty." Carlos R. Leffler v. Hutter, 696
A.2d 157, 162 (Pa. Super. Ct. 1997).
The defendant argues that the plaintiff is only entitled to the money retained at the
time of her breach. (Defendants Brief in Support of Preliminary Objections to Plaintiffs
Complaint at 3.) Because the defendant's deposit check was not honored by the drawee,
she contends there is nothing for the plaintiffs to retain. (Defendants Brief in Support of
Preliminary Objections to Plaintiffs Complaint at 4.) The defendant counters that the
plaintiffs are attempting to circumvent the liquidated damages provision. (Defendants
Brief in Support of Preliminary Objections to Plaintiffs Complaint at 4.)
"Where, in an agreement of sale of real estate, there is a provision for liquidated
damages and the vendee repudiates the agreement the vendor is entitled to the sum agreed
upon as liquidated damages." Tudesco v. Wilson, 60 A.2d 388, 390 (Pa. Super. 1948).
In Tudesco, buyers tendered deposit monies by way of two separate checks. 60 A.2d at
390. The buyers stopped payment before the sellers could cash the checks. Id. at 390.
The agreement of sale contained a liquidated damages provision that provided the deposit
made by the buyer may be retained by the seller. Id. at 390. The defendants argued that
because they canceled the checks the plaintiffs had nothing to retain. Id. at 390. The
Pennsylvania Superior Court found for the sellers, noting:
There is no merit to [the] argument that the word retained as used in
the agreement restricts the liquidated damages to the retention of the
cash deposit... When the vendee stopped payment on the checks there
was nothing for the vendors to retain. Of course, the vendors could
have brought action on the checks had they chosen to do so. But they
chose, as was their right...to seek recovery of the sum specified in the
liquidated damage clause of the agreement. To bar this action, as the
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vendee would have us do, by his narrow construction of the liquidated
damage clause...would do violence to the clear intention of the
parties...
Id. at 390, emphasis in original.
While the checks in Tudesco were canceled by the vendees, the check in the
present case "bounced." There is no Pennsylvania precedent regarding bad deposit
checks vis-h-vis a liquidated damage provision, however other jurisdictions have awarded
sellers the full amount of the deposit when the buyer's check was not honored. Brodsky
v. Linder_, 118 A.2d 803 (D.C. 1955)( allowing recovery of liquidated damages in the
amount of the deposit of an unpaid check.); Mori v. Bomac Industries, 358 So.2d 47 (Fla.
Dist. Ct. App. 1978)( holding liquidated damages provision was not nullified when
money was not deposited because check for that amount was returned for insufficient
funds). Writing a bad check and stopping payment on a check are actions which are both
attributable to the check writer. "A party cannot take advantage of his own wrongful act
to set up his default or to nullify his contract or work its forfeiture." Tudesco, 60 A.2d at
391. Because this case may present just such a scenario, we decline to sustain a
demurrer. ~
Defendant also contends that awarding the plaintiff $10,000.00 would amount to
an unlawful penalty and not a reasonable expectation of plaintiff' s expected loss. This
matter is more properly left to the finder of the facts.
~ The complaint alleges that $10,000.00 was paid as a "deposit." We note that, though the agreement was
signed on July 29, 2001, the deposit was not due until August 6, 2001. Whether this circumstance has any
impact on the ultimate disposition of this case must await a more developed record.
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02-3434 CIVIL
ORDER
AND NOW, this 18th day of June, 2003, the preliminary objections of the
defendant, Sophany Reth, are DENIED.
BY THE COURT,
Cory J. Snook, Esquire
For the Plaintiffs
James M. Strong, Esquire
For the Defendant Reth
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Kevin A. Hess, J.
ROBERT H. LANDINO and
FRANCES B. LANDINO,
Plaimiffs
VS.
SON PAUCH, individually, and
SOPHANY RETH, individually,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
02-3434 CIVIL
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
IN RE: PRELIMINARY OBJECTIONS OF DEFENDANT, SOPHANY RETH
BEFORE BAYLEY AND HESS, JJ.
ORDER
AND NOW, this 18th day of June, 2003, the preliminary objections of the
defendant, Sophany Reth, are DENIED.
BY THE COURT,
Cory J. Snook, Esquire
For the Plaimiffs
James M. Strong, Esquire
For the Defendant Reth
Kevin A. Hess, J.
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