2007 East Meadows, LP v. RCM Phoenix Partners, LLC (mem. dec.)

CourtIndiana Court of Appeals
DecidedJanuary 20, 2016
Docket49A05-1407-PL-300
StatusPublished

This text of 2007 East Meadows, LP v. RCM Phoenix Partners, LLC (mem. dec.) (2007 East Meadows, LP v. RCM Phoenix Partners, LLC (mem. dec.)) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
2007 East Meadows, LP v. RCM Phoenix Partners, LLC (mem. dec.), (Ind. Ct. App. 2016).

Opinion

MEMORANDUM DECISION

Pursuant to Ind. Appellate Rule 65(D), Jan 20 2016, 10:35 am this Memorandum Decision shall not be regarded as precedent or cited before any court except for the purpose of establishing the defense of res judicata, collateral estoppel, or the law of the case.

ATTORNEYS FOR APPELLANT ATTORNEY FOR APPELLEE Thomas F. Bedsole F. Anthony Paganelli Maggie L. Smith Paganelli Law Group Frost Brown Todd, LLC Indianapolis, Indiana Indianapolis, Indiana

IN THE COURT OF APPEALS OF INDIANA

2007 East Meadows, LP, January 20, 2016 Appellant-Defendant/Counterclaim Court of Appeals Case No. Plaintiff, 49A05-1407-PL-300

v. Appeal from the Marion Superior Court

RCM Phoenix Partners, LLC, The Honorable James B. Osborn, Judge Appellee-Plaintiff/Counterclaim Trial Court Cause No. Defendant 49D14-0807-PL-34494

Mathias, Judge.

[1] 2007 East Meadows, LP (“Meadows”) appeals from the order of the Marion

Superior Court granting summary judgment in favor of RCM Phoenix Partners,

LLC (“Phoenix”) in Meadows’s counter-claim against Phoenix alleging breach

Court of Appeals of Indiana | Memorandum Decision 49A05-1407-PL-300 | January 20, 2016 Page 1 of 18 of contract and fraud and requesting specific performance. On appeal,

Meadows presents four issues, which we restate as whether the trial court

properly granted summary judgment in favor of Phoenix on Meadows’ claims

of breach of contract and fraud and its request for specific performance.

[2] We affirm.

Statement of Facts

[3] Phoenix is a Connecticut-based company that owns the Phoenix Apartments

(“the Apartments”), a housing complex in Indianapolis.1 The Apartments are

located in a depressed and economically distressed area and serve to house

poorer residents through the U.S. Department of Housing and Urban

Development (“HUD”). HUD paid Phoenix a monthly “Housing Assistance

Payment” (“HAP”) pursuant to an agreement between HUD and Phoenix.

[4] In July of 2007, Phoenix entered into a written Purchase and Sale Agreement

(“the Agreement”) with Texas-based Eureka Holdings Acquisitions, LP

(“Eureka”), in which Eureka agreed to purchase the Apartments for a price of

$9,050,000. Three months later, on September 5, 2007, Eureka assigned all of

its rights under the Agreement to Indiana-based Meadows.

[5] The Agreement contained at least three essential requirements: (1) that HUD

approve assigning the HAP to Meadows; (2) Meadows tendering a cash

1 The apartments are located south of 42nd Street, in the area between North Keystone Avenue and North Sherman Drive, east of the State Fairgrounds.

Court of Appeals of Indiana | Memorandum Decision 49A05-1407-PL-300 | January 20, 2016 Page 2 of 18 payment at closing; and (3) Meadows assuming roughly $6,850,000 of

Phoenix’s loan and mortgage obligations (“the Mortgage”) with Wachovia

Bank (“Wachovia”). Thus, the contract required Meadows to pay the purchase

price through a combination of cash and assuming the existing multi-million

dollar Wachovia mortgage. Meadows had secured the cash required for closing

and presumed that Wachovia’s approval of the assignment of the Mortgage

would be a “formality” because the loan was secured by both the real property

and the HUD Housing Assistance Payment.

[6] The Agreement called for a closing date in October 2007. However, as of

October 1, 2007, Wachovia had not yet approved Meadows to assume the

Mortgage. Accordingly, Meadows’ counsel sent an email to Phoenix’s counsel

invoking a provision of the Agreement that allowed the closing date to be

extended by thirty days if the lender had not yet approved assumption of the

Mortgage. The closing date was then set for late in November 2007. However,

by late October, Meadows had still not received approval and became

concerned that the approval process was taking too long. In an email sent on

October 31, 2007, Meadows indicated that it might need another extension of

the closing date to secure the approval from Wachovia. On November 19, 2007,

Phoenix’s counsel sent a letter to Meadows’s counsel complaining about the

delays in securing financing and threatening to cancel the transaction. The

following day, Meadows requested another extension of the closing date, and

the parties eventually agreed to amend the Agreement, with the closing date

Court of Appeals of Indiana | Memorandum Decision 49A05-1407-PL-300 | January 20, 2016 Page 3 of 18 changed to be “on or before January 7, 2008. TIME BEING OF THE

ESSENCE.” Appellant’s App. p. 128.

[7] Meadows was still having trouble obtaining Wachovia’s approval of the

mortgage assumption, and on November 28, 2007, Meadows’ chief financial

officer Mike Wallis (“Wallis”) accused Wachovia in an email of “sitting on its

hands” with regard to the mortgage assumption request. In an internal memo

on that same date, Wallis informed his colleagues at Meadows that Wachovia

had all of the information it needed to approve the loan, yet Wachovia was not

even willing to send Meadows the draft loan documents for Meadows’ counsel

to review.

[8] Tragically, at some point in November 2007, a three-year-old child was killed

by her parents in one of the units at the Apartments.2 This incident caused a

public outcry, and on December 5, 2007, the Indianapolis Housing Authority

began an enforcement action3 against Phoenix regarding the condition of the

Apartments. The enforcement action sought “[r]ecovery of Federal Funds due

to the allegations of civil and/or criminal fraud,” “[h]ousing fraud due to a

number of reasons, including alleged poor housing conditions, failure to

disclose ownership change, and violations of the HAP agreement.” Appellant’s

App. p. 215. The action sought changes in the management and operation of

2 No evidence indicates that this incident had any connection with Phoenix. 3 Meadows insists upon referring to the enforcement action as a “criminal” action, whereas Phoenix contends that it was merely a “civil” enforcement action.

Court of Appeals of Indiana | Memorandum Decision 49A05-1407-PL-300 | January 20, 2016 Page 4 of 18 the Apartments in addition to recovery of governmental funds the Apartments

had received. Id.

[9] One of the key points of contention in the present case is whether Phoenix

notified Meadows of this incident. Phoenix claims, and the trial court found,

that Phoenix did notify Meadows regarding the child’s death and the

subsequent enforcement action. Meadows, however, designated some evidence

that it learned of the enforcement action as it was making the final preparations

for closing.

[10] Meadows also designated evidence indicating that, prior to the closing date,

HUD informed it that it would not approve of the transfer of the HAP because

of the enforcement action against Phoenix.4 Meadows also designated evidence

indicating that it could not obtain Wachovia’s approval without HUD agreeing

to transfer the Housing Assistance Payment.

[11] By December 7, 2007, Wachovia had still not approved of Meadows’s request

to assume the mortgage on the Apartments. Even so, that same day,

Meadows’s counsel emailed Phoenix’s counsel informing him that Meadows

hoped to have the approval documents soon. However, approval was not

forthcoming, and on the scheduled closing date, January 7, 2008, Meadows’

counsel asked Phoenix for another thirty-day extension of the closing date.

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