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Patterson v. Golden Feathers Realty Services, Inc.

Citation: 31 F. App'x 495Docket: No. 01-55317; D.C. No. CV-00-07439-GAF

Court: Court of Appeals for the Ninth Circuit; March 6, 2002; Federal Appellate Court

Narrative Opinion Summary

To establish a breach of contract claim, a valid contract must exist. In Careau Co. v. Sec. Pac. Bus. Credit, Inc., the court held that a bid proposal for real property at a HUD auction does not constitute a contract under California law unless it is in writing and signed by all parties involved, per Cal. Civ. Code § 1624(a)(3). The appellant's bid proposal lacked the necessary signatures from HUD or any other binding party, resulting in the absence of a contract and, consequently, no breach could occur. The judgment is affirmed, and the disposition is not intended for publication or citation in this circuit, except as allowed by Ninth Circuit Rule 36-3.

Legal Issues Addressed

Breach of Contract Requirements

Application: The court determined that a breach of contract claim requires the existence of a valid contract, which was not present in this case due to the absence of necessary signatures.

Reasoning: To establish a breach of contract claim, a valid contract must exist.

Contract Formation under California Law

Application: The court applied California law, specifically Cal. Civ. Code § 1624(a)(3), to determine that a bid proposal for real property is not a contract unless it is in writing and signed by all parties.

Reasoning: In Careau Co. v. Sec. Pac. Bus. Credit, Inc., the court held that a bid proposal for real property at a HUD auction does not constitute a contract under California law unless it is in writing and signed by all parties involved, per Cal. Civ. Code § 1624(a)(3).

Non-Publication and Citation Restriction

Application: The judgment in this case is not intended for publication or citation except as allowed by specific circuit rules, limiting its precedential value.

Reasoning: The judgment is affirmed, and the disposition is not intended for publication or citation in this circuit, except as allowed by Ninth Circuit Rule 36-3.