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F.W. Leisure Industries, Inc. v. Cook Paint & Varnish Co.

Citations: 153 Ariz. 342; 736 P.2d 825; 1987 Ariz. App. LEXIS 387Docket: No. 2 CA-CV 5962

Court: Court of Appeals of Arizona; March 31, 1987; Arizona; State Appellate Court

Narrative Opinion Summary

The case involves an appeal from a summary judgment in favor of Cook Paint and Varnish Company in a breach of contract action initiated by F.W. Leisure Industries, Inc. The dispute arose over warranties provided by Cook to F.W. Associates, a third-party manufacturer of fiberglass whirlpool spas, which were subsequently acquired by F.W. Leisure through an Assets Purchase Agreement. A critical issue was the validity of an 'Assignment of Cause of Action' that transferred the claim from F.W. Associates to F.W. Leisure. Cook contended that the assignment was fabricated, but the appellate court held that as long as the assignment was executed before trial and did not prejudice Cook, its timing was immaterial. The court concluded that F.W. Leisure was the real party in interest and found no evidence to invalidate the assignment despite its back-dating. Consequently, the appellate court reversed the trial court's summary judgment, remanding the case for further proceedings, and thus allowing F.W. Leisure to continue its action against Cook. The decision underscores the legal principle of ensuring the real party in interest is permitted to sue, emphasizing the importance of the substance over procedural formalities in assignments of claims.

Legal Issues Addressed

Real Party in Interest

Application: The appellate court determined that F.W. Leisure Industries, Inc. was the real party in interest entitled to pursue the breach of contract claim against Cook Paint and Varnish Company.

Reasoning: The appellate court disagreed with Cook, asserting that the timing of the assignment's execution was irrelevant as long as it occurred before trial and did not prejudice Cook.

Summary Judgment Standard

Application: The appellate court reversed the trial court's summary judgment, finding that the lower court erred in its determination regarding the proper party to sue.

Reasoning: The appellate court reversed the trial court's summary judgment and remanded the case for further proceedings, with concurrence from the Chief Justice and another judge.

Validity of Assignment

Application: The court confirmed that the assignment of the cause of action from F.W. Associates to F.W. Leisure was valid despite allegations of back-dating.

Reasoning: The court found no evidence to support Cook's claim of fabrication beyond the back-dating of the document, which did not undermine its validity.