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Wells Fargo Bank, N.A. v. Nancy J. Nevins & re/max West Realty, Inc.

Citation: Not availableDocket: 4-055 / 13-0944

Court: Court of Appeals of Iowa; March 12, 2014; Iowa; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, an appeal was made by an individual against a district court's ruling that held her personally liable for a business line of credit extended by a financial institution. The appellant, as the owner and president of the business, had orally guaranteed the credit line, which the district court concluded was enforceable despite her argument that the statute of frauds should prevent its enforcement. The court determined that the oral guarantee was an original promise, integral to securing the credit, thus not barred by the statute of frauds. Additionally, the court found an error in the district court's reliance on an unpublished dissolution of marriage case but considered it harmless, as there was substantial evidence showing the appellant benefited from the credit line through her business role and salary. Ultimately, the court upheld the district court's decision, affirming the appellant's personal liability for the outstanding debt of $103,709.10, emphasizing the original nature of her promise and her derived benefits from the credit advances.

Legal Issues Addressed

Harmless Error Doctrine

Application: The court acknowledged the erroneous citation of an unpublished dissolution of marriage decision but deemed it harmless due to sufficient evidence of Nevins' benefit from the credit line.

Reasoning: The court acknowledged that referencing the dissolution case was erroneous but deemed the error harmless.

Personal Liability for Business Debt

Application: Nevins was held personally liable for the line of credit due to her oral guarantee and the benefit she derived from the credit, despite the company defaulting on payments.

Reasoning: The district court found Nevins liable for the outstanding amount of $103,709.10.

Statute of Frauds and Oral Guarantees

Application: The court found that the statute of frauds did not bar the enforcement of Nevins' oral guarantee because it constituted an original promise, integral to obtaining credit.

Reasoning: The court ruled that the statute of frauds did not bar the oral guarantee, as it constituted an original promise.