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Baumann v. Intracoastal Pacific Ltd. Partnership

Citations: 619 So. 2d 403; 1993 Fla. App. LEXIS 5959Docket: No. 92-2545

Court: District Court of Appeal of Florida; June 1, 1993; Florida; State Appellate Court

Narrative Opinion Summary

In a contractual dispute involving the disbursement of escrowed funds from a real estate transaction, the appellate court reversed a trial court's summary judgment in favor of Intracoastal Pacific Limited Partnership. The Baumanns, sellers of the Intracoastal Mall, argued that Intracoastal's bad faith actions led to the failure of crucial lease negotiations with Ethan Allen, which was a condition for releasing escrowed funds. Intracoastal, asserting that the lease would not have been finalized regardless of negotiations, sought partial summary judgment, which was initially granted but later vacated due to procedural deficiencies. The trial court eventually ordered the disbursement of the escrow funds despite existing factual disputes. On appeal, the court reversed the disbursement order, underscoring the unresolved issues concerning the lease negotiations and bad faith allegations. The case was remanded for further proceedings, emphasizing that the summary judgment was inappropriate given the contested facts and the premature resolution of the escrow conditions.

Legal Issues Addressed

Breach of Contract and Bad Faith

Application: The Baumanns alleged that Intracoastal acted in bad faith, leading to the failed lease negotiations with Ethan Allen, which constituted a breach of contract.

Reasoning: The Baumanns sued Intracoastal for breach of contract in May 1990, claiming bad faith actions by Intracoastal led to the failure of the lease negotiations.

Escrow Agreement Conditions

Application: The escrow funds were contingent upon leasing conditions that were not met due to unresolved disputes regarding the conduct of the parties.

Reasoning: Notably, an escrow account for Ethan Allen, totaling $796,560, was contingent upon finalizing a lease, which ultimately did not occur as Ethan Allen chose a different location.

Summary Judgment Standards

Application: Despite the initial grant of partial summary judgment to Intracoastal, the appellate court found significant factual disputes that precluded such a ruling.

Reasoning: The appellate court highlighted that there were significant factual disputes regarding the lease negotiations and bad faith claims, and emphasized that the disbursement order was premature as it did not resolve all issues in the case.