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LeBlanc v. New England Raceway, LLC

Citations: 976 A.2d 750; 116 Conn. App. 267; 2009 Conn. App. LEXIS 350Docket: AC 29724

Court: Connecticut Appellate Court; August 4, 2009; Connecticut; State Appellate Court

Narrative Opinion Summary

The case concerns a contract dispute arising from a failed real estate transaction intended for the development of a NASCAR racetrack. The plaintiffs sought to enforce a contract with the defendants, alleging breach and sought specific performance. The defendants argued the contract was unenforceable due to unmet zoning contingencies. At trial, the court ruled in favor of the defendants, finding that the plaintiffs failed to prove contractual modifications were authorized by the defendants' principal. The court determined that the real estate agent lacked authority to bind the defendants in contractual changes, particularly regarding the closing dates. The plaintiffs' appeal was rejected, as the appellate court affirmed the trial court's factual findings and legal conclusions, including the authority of agents and the burden of proof for contract modifications. Additionally, the court's decision to allow the defendants to amend their pleadings was not preserved for appeal, precluding any review. Ultimately, the original judgment was upheld, and the plaintiffs' arguments were dismissed as lacking merit.

Legal Issues Addressed

Amendment of Pleadings

Application: The court allowed the defendants to amend their answer to the complaint, a decision not preserved for appeal by the plaintiffs, thus precluding review.

Reasoning: The plaintiffs challenge the court's decision to allow the defendants to amend their answer to the complaint. However, this claim was not preserved at trial, leading the appellate court to decline review.

Appellate Review of Factual Findings

Application: The plaintiffs' appeal was rejected as the appellate court found no merit in challenging the trial court's factual findings regarding contract contingencies and witness credibility.

Reasoning: The plaintiffs' appeal, which challenged the court's factual findings, was deemed meritless under established appellate review principles.

Authority of Real Estate Agents in Contractual Modifications

Application: The court found that Corn, the real estate agent, lacked actual, implied, or apparent authority to bind the defendants in contractual modifications, particularly concerning the closing date.

Reasoning: The court clarified that it did not find the dual agency agreement revoked Corn's authority; rather, it concluded that Corn lacked actual, apparent, or implied authority to bind the defendants, partly based on the dual agency agreement.

Burden of Proof in Contract Modifications

Application: The court clarified that the burden of proof was correctly placed on the plaintiffs to demonstrate that Arganese, representing New England Raceway, LLC, approved changes to the May 12, 2004 contract.

Reasoning: The trial court denied the plaintiffs' motion for reconsideration and clarified that the burden of proof was correctly placed on them to demonstrate that Arganese, representing New England Raceway, LLC, approved changes to the May 12, 2004 contract.

Implied and Apparent Authority of Agents

Application: The court determined that Corn did not have implied or apparent authority to enter into contracts on behalf of New England Raceway, LLC, as Arganese was the ultimate authority and did not consent to such actions.

Reasoning: The court's ruling that Corn lacked both actual and implied authority to enter into contracts on behalf of New England Raceway, LLC, was upheld.