Thanks for visiting! Welcome to a new way to research case law. You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.
Henley's Wholesale Meats, Inc. v. Walt Bennett Ford, Inc.
Citations: 4 Ark. App. 362; 631 S.W.2d 316; 1982 Ark. App. LEXIS 753Docket: CA 81-241
Court: Court of Appeals of Arkansas; April 14, 1982; Arkansas; State Appellate Court
The case revolves around whether the trial judge correctly directed a verdict for Walt Bennett Ford, Inc., at the conclusion of Henley’s Wholesale Meats, Inc.'s case. Henley argues that it established a prima facie case of misrepresentation, requiring Bennett to provide evidence to counter this claim. In contrast, Bennett asserts that Henley failed to present competent proof of a false statement or reliance on such a statement. Bennett's appeal invokes Rule 52 of the Arkansas Rules of Civil Procedure, questioning whether the trial court's findings were against the preponderance of evidence. However, the correct standard requires evaluating the evidence in the light most favorable to Henley and determining if it could present a question of fact for a jury. The court noted that it is inappropriate to weigh evidence at this stage, and if Henley’s evidence, viewed favorably, could suggest a jury question, the motion for a directed verdict should be denied. A factual issue was identified regarding representations made by Bennett's salesman, specifically about the suitability of a one-speed rear axle for Henley's delivery trucks, which Henley claimed were inadequate for their intended purpose. Henley’s president testified that the salesman, aware of the trucks’ intended use, assured that the one-speed axle would suffice. Testimony from a Ford representative supported this claim. Despite Bennett's argument that the salesman’s statements were merely opinions and not deceitful, the court found that Henley’s evidence could imply misrepresentation warranting jury consideration. In Fausett Company, Inc. v. Bullard, the court established that a plaintiff in a misrepresentation case does not need to prove the defendant's intent to deceive; fraudulent representations are deemed as such if made by someone who knows them to be false or asserts them as true without knowledge. The court emphasized that a buyer can rely on statements from a seller with specialized knowledge. In the current case, evidence indicated that Bennett’s salesman was aware that Henley believed a two-speed rear axle was required for intended deliveries but insisted that a one-speed axle would suffice. Favoring Henley’s position, the court noted that the salesman possessed peculiar knowledge about the trucks' capabilities. It was inferred that the trucks were not suitable for highway use, contradicting their intended purpose. The court rejected Bennett's argument that the salesman’s assertion was merely an opinion. Although Henley established a prima facie case, the court did not grant a judgment in favor of Henley, allowing for a trial on the merits. Additionally, Henley raised issues regarding revocation of acceptance and warranties, which were not addressed due to procedural grounds, and the court allowed these issues to be developed upon remand. The decision was reversed and remanded for further proceedings.