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Timothy O'Keefe and Sharon O'Keefe v. Barry Gordon, Roger Farley, and Plantation Title

Citation: Not availableDocket: M2011-01476-COA-R3-CV

Court: Court of Appeals of Tennessee; June 18, 2013; Tennessee; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In a real estate dispute, the plaintiffs, involved in purchasing homes for resale, sued multiple parties including the home seller and their investment advisor, following the acquisition of a home with undisclosed defects. The seller was found liable for intentional and negligent misrepresentation, breach of warranties, and violations of the Tennessee Consumer Protection Act (T.C.P.A.), while the investment advisor was liable for intentional misrepresentation. The trial court rescinded the sales contract and awarded damages and attorney fees, leading to appeals by the seller and advisor. The appellate court upheld the trial court's decision, confirming the seller's liability under the T.C.P.A. for failing to disclose a septic system defect, and ruled against the advisor for intentional misrepresentation. The court applied the 'benefit of the bargain' rule for damages, rejecting the advisor's claim that the plaintiffs failed to mitigate their losses. The judgment was affirmed, with no errors found in the proceedings, resulting in significant financial liabilities for the defendants.

Legal Issues Addressed

Benefit of the Bargain Rule

Application: The court upheld damages calculated based on the difference between the property's actual value and the value as represented, rejecting any duty to mitigate damages from intentional misrepresentation.

Reasoning: The appropriate method for calculating damages in cases of fraudulent misrepresentation is the 'benefit of the bargain' rule, which allows recovery of the difference between the actual value of the property received and the value it would have had if the defendant's representations were accurate.

Intentional and Negligent Misrepresentation

Application: The jury found that the seller and investment advisor made false representations concerning the property, which led to the plaintiffs suffering damages.

Reasoning: The jury found the seller liable for intentional and negligent misrepresentation, negligence, breach of warranties, and violations of the Tennessee Consumer Protection Act, while Gordon was found liable for intentional misrepresentation.

Rescission of Contract and Damages

Application: The trial court ordered rescission of the sales contract and awarded damages and attorney fees due to misrepresentations and statutory violations.

Reasoning: The trial court ordered the rescission of the sales contract, awarded damages and attorney fees to the O’Keefes due to the seller's Consumer Protection Act violations, and imposed damages against the investment advisor.

Standard for Reviewing Jury Verdicts

Application: The appellate court affirmed the trial court’s judgment, finding that the jury's conclusions were supported by material evidence.

Reasoning: The Court of Appeals affirmed the trial court’s judgment, finding no errors in the proceedings.

Tennessee Consumer Protection Act Violations

Application: The court held the seller liable under the Tennessee Consumer Protection Act for failing to disclose a defect in the home, despite the seller's claims of constructive notice through public records.

Reasoning: Material evidence supports the jury’s verdict that Mr. Farley violated the Tennessee Consumer Protection Act (T.C.P.A.) by failing to disclose a defect in the home sold to the Plaintiffs.