Arnold v. Moore

980 P.2d 291, 96 Wash. App. 488
CourtCourt of Appeals of Washington
DecidedJuly 16, 1999
DocketNo. 23446-7-II
StatusPublished

This text of 980 P.2d 291 (Arnold v. Moore) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Arnold v. Moore, 980 P.2d 291, 96 Wash. App. 488 (Wash. Ct. App. 1999).

Opinion

Morgan, J.

This case involves a real estate contract. The question is whether the seller had a duty to notify a transferee of the purchaser’s interest, of whom the seller had actual knowledge, of the seller’s intent to forfeit the purchaser’s interest. In our view, the answer is yes.

In 1984, Roland E. Moore sold the Tipperary Tavern to William O. Price. The sale was by real estate contract. Moore retained a seller’s interest. Hereafter, we refer to the tavern as “the property.”

In 1991, William Price sold his interest in the property to Carol Gager. The sale was by real estate contract. Price retained a seller’s interest in the Price-Gager contract, and a part of his purchaser’s interest in the Moore-Price contract.

In 1993, William Price died. He left a will devising his interest in the property to his children, Kenneth Price and Patricia Russell. The will was admitted to probate, and Kenneth was named personal representative.

In October 1994, Russell assigned to Gerald D. Arnold, the plaintiff, her undivided one-half share of William Price’s interest in the property.1 In August 1995, documents disclosing the assignment were filed in the William Price probate file. In April 1996, Kenneth Price assigned his undivided one-half share to Arnold.

[490]*490In July 1996, the county started tax foreclosure proceedings. It notified Arnold as well as Moore.

In November 1996, Arnold called the county to obtain a payoff figure for the overdue taxes. The county told him that Moore had paid the taxes earlier the same day. It also gave him the phone number of Moore’s attorney.

A few minutes later, Arnold called the office of Moore’s attorney. He explained to someone there that he had an interest in the property, and that he wanted to pay the overdue taxes. He left his address and his phone numbers. He also obtained Moore’s phone number.

Still on the same day, Arnold spoke to Moore. According to Arnold’s later declaration, Moore

seemed not to be interested in my intentions or who I was. I explained everything to him fully, and told him that I would reimburse him at once for all of the taxes, interest and other monies he could substantiate that were due and owing. I also gave him my home address and both of my phone numbers.[2]

Over the next few months, Arnold left several messages for Moore, but Moore did not respond.

In December 1996, Moore’s attorney reviewed the William Price probate file. At that time, the file showed that Russell had assigned her interest in the property to Arnold, and that the personal representative had distributed Russell’s interest to Arnold.

In January 1997, Moore recorded a notice of intent to forfeit the real estate contract between him and William Price. Although he served the notice on Kenneth Price and Patricia Russell, he did not serve it on Arnold.

In April 1997, Moore recorded a declaration that purported to forfeit William Price’s interest in the property. In June 1997, Arnold sued to void the declaration. He claimed that he was entitled to notice of Moore’s intent to forfeit, and that he had not received such notice.

[491]*491In January 1998, Moore moved for summary judgment. He did not dispute that Arnold had not received notice, but he did claim that Arnold was not entitled to notice. In June 1998, the trial court granted the motion, and Arnold filed this appeal.

A seller may forfeit the purchaser’s rights under a real estate contract only if the seller “giv[es] and record[s] the required notices.”3 The seller must give the “required notices” to “each purchaser last known to the seller,” and to “each person who, at the time the notice of intent to forfeit is recorded, is the last holder of record of a purchaser’s interest.”4 If the seller does not give the required notices, the purported forfeiture is “void”5 and may be set aside at the behest of any “person entitled to be given the required notices.”6

Arnold contends he was entitled to notice because he was a “purchaser last known” to Moore. Alternatively, he contends he was entitled to notice because he was a “holder of record.” We do not reach the second contention, because the first is dispositive. In addressing the first, we consider (1) whether Arnold was a “purchaser,” and (2) whether Arnold was a purchaser “last known” to Moore.

I

RCW 61.30.010(7) defines the term “purchaser.” It provides:

[The term] “[plurchaser” means the person denominated in a real estate contract as the purchaser of the property or an interest therein or, if applicable, the purchaser’s successors or assigns in interest to all or any part of the property, whether by voluntary or involuntary transfer or transfer by operation [492]*492of law. If the purchaser’s interest in the property is subject to a proceeding in probate, a receivership, a guardianship, or a proceeding under the federal bankruptcy laws, “purchaser” means the personal representative, the receiver, the guardian, the trustee in bankruptcy, or the debtor in possession, as applicable. However, “purchaser” does not include an assignee or any other person whose only interest or claim is in the nature of a lien or other security interest.

Here, William Price was the person denominated in the original Moore-Price contract. Russell was his successor by operation of law. Arnold was Russell’s assignee by voluntary transfer. Accordingly, Arnold was a “purchaser” within the meaning of RCW 61.30.010(7).

In reaching this conclusion, we necessarily rule that the second sentence of RCW 61.30.010(7) has no impact on Moore’s duty to give notice to Arnold. To explain why, we return to the statute.

RCW 61.30.010(7) uses the word “purchaser” inconsistently. Its first sentence provides, “ ‘Purchaser ’ means the person denominated in a real estate contract as the purchaser of the property or an interest therein or, if applicable, the purchaser’s successors or assigns in interest to all or any part of the property, whether by voluntary or involuntary transfer or transfer by operation of law.” Its third sentence provides, “ ‘[P]urchaser’ does not include an assignee or any other person whose only interest or claim is in the nature of a lien or other security interest.” Where we have added bold print, the word “purchaser” clearly means not only the original buyer, but also the original buyer’s successors and assignees.7 Where we have [493]*493added underlining, the word “purchaser” clearly means the original buyer only.8

Arguably, this inconsistency affects the statute’s second sentence. That sentence provides in part, “If the purchaser’s interest in the property is subject to a proceeding in probate . . ., ‘purchaser’

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Bluebook (online)
980 P.2d 291, 96 Wash. App. 488, Counsel Stack Legal Research, https://law.counselstack.com/opinion/arnold-v-moore-washctapp-1999.