Bennett v. Cell-Pest Control, Inc.

701 So. 2d 1122, 1997 Ala. Civ. App. LEXIS 301, 1997 WL 174844
CourtCourt of Civil Appeals of Alabama
DecidedApril 11, 1997
Docket2950894
StatusPublished

This text of 701 So. 2d 1122 (Bennett v. Cell-Pest Control, Inc.) is published on Counsel Stack Legal Research, covering Court of Civil Appeals of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bennett v. Cell-Pest Control, Inc., 701 So. 2d 1122, 1997 Ala. Civ. App. LEXIS 301, 1997 WL 174844 (Ala. Ct. App. 1997).

Opinion

THOMPSON, Judge.

This action for fraudulent misrepresentation, breach of contract, and negligent inspection was originally assigned to a former judge on the court, and recently was reassigned.

On January 21,1993, the Griffins, husband and wife, purchased a home in Moulton. In connection with that sale, a termite inspection was performed; it revealed weather rot on the floor joist above the crawl space. The Griffins lived in the house until the summer of that year, when they decided to return to their home in Athens.

On the weekend of July 4, 1993, James Bennett and his wife Diana Bennett visited the Griffins’ home as prospective purchasers. Although the Bennetts were represented by a real estate agent, the agent did not accompany them on their first visit to the Griffin’s house. The Bennetts inspected the house for about two hours on this first visit and discussed the purchase of the house with Mr. Griffin. Mr. Griffin reported to them that the ceiling fans did not work and that there was a hole in the central vacuum hose. When the Bennetts asked him if there was anything else he knew about the house that they should know, Mr. Griffin replied “No.”

The Bennetts signed and presented a sales contract on July 6,1993, which contained the following language:

[1123]*1123“13. COMPLETE AGREEMENT: The Seller and Buyer hereby acknowledge and confirm that this contract states the entire agreement between the parties and there has been no representations, covenants, statements or warranties, unless expressly stated herein made to the buyer or seller or any person whomever. Buyer and Seller have entered into this agreement based upon their own inspection and personal knowledge of the property and any financing arrangements concerning said property and neither party has relied upon any representations or statements of any person whomever unless said representations or statements are expressly written herein.
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“15. THIS IS A LEGAL INSTRUMENT. IF NOT UNDERSTOOD, LEGAL, TAX OR OTHER COUNSEL SHOULD BE CONSULTED BEFORE SIGNING.”

The Griffins accepted the sales contract with no changes.

Mr. Bennett testified at trial that when he signed the contract he understood that it was contingent upon the mortgage company’s doing inspections on the house. On August 27, 1993, Cell-Pest Control, Inc. (“Cell-Pest”), was hired to perform an inspection of the home and provide a clearance letter stating that the home was free of visible signs of active or previous infestations of wood-destroying organisms. This letter was required by the Veterans Administration in order for the Bennetts to qualify for a VA loan.

The sale of the house was consummated at a closing that took place on August 31, 1993. At closing, the Griffins produced the “Official Alabama Infestation Inspection Report” completed by Cell-Pest, which stated that the house was free of visible evidence of active or previous infestation of wood-destroying organisms. After moving into the house, the Bennetts discovered water damage to a wall and to some of the subflooring and floor joists. An estimate from a contractor for repair of this damage was approximately $30,400.

Ten months later, the Bennetts sued the Griffins, alleging that the Griffins had made a material misrepresentation regarding the structural soundness of the house. In addition, the Bennetts sued Cell-Pest, claiming to be third party beneficiaries of a contract between the Griffins and Cell-Pest, alleging breach of contract, claiming that Cell-Pest had performed a negligent inspection of the house. Following complete discovery, the judge entered a summary judgment in favor of Cell-Pest and the Griffins.

The Bennetts appeal, making the following arguments: (1) that the summary judgment was improper as to the misrepresentation claim against the Griffins because the Ben-netts say they produced documentary evidence that the Griffins had knowledge of the floor rot and failed to reveal this fact to, the Bennetts when the Bennetts inquired if there was anything further that they should know about the house; and (2) that the summary judgment was improper on the claims of misrepresentation and negligence against Cell-Pest, where Cell-Pest produced a clearance letter stating that the house had no active or previous signs of wood-decaying fungus and the Bennetts say they relied on these representations and purchased the house and discovered damage caused by wood-destroying organisms shortly after the real estate closing.

We affirm the summary judgment as to the claims against the Griffins. The Ben-netts failed to establish a claim of misrepresentation against the Griffins. The doctrine of “caveat emptor” applies to the sale of a used residence. Ray v. Montgomery, 399 So.2d 230, 233 (Ala.1980). Our Supreme Court stated that this doctrine did not apply under circumstances when the purchaser of a used house inquires directly of the seller or the seller’s agent, prior to the closing, about a material defect or condition of the home. Cato v. Lowder Realty Co., 630 So.2d 378, 383 (Ala.1993) (citing Fennell Realty Co. v. Martin, 529 So.2d 1003, 1005 (Ala.1988)). The Cato court explained that if the seller or his agent was asked about a specific defect and assumed the obligation to conduct an investigation to obtain an answer to the defect inquired about, and disclosed this answer to the buyer, the law imposed on him a duty [1124]*1124to truthfully disclose all material facts revealed by the investigation. Id. In addition, if the seller or agent has knowledge of a material defect that would affect health or safety, and the defect is not readily observable by the purchaser, the law imposes a duty to disclose the defect. Id.

The undisputed evidence in the record was that the Bennetts questioned the Griffins as to whether there was anything the Bennetts should know about the house and Mr. Griffin replied “No.” The question posed by the Bennetts was far too vague to bring this case within the “direct inquiry of a specific defect” exception to the general rule of “caveat emptor.”

In a ease where the purchasers asked the sellers if there were any problems with the house and the seller replied no, our Supreme Court affirmed a summary judgment in favor of the defendant, holding that such a statement constituted an expression of an opinion, not a representation of fact. Cornelius v. Austin, 542 So.2d 1220, 1223 (Ala.1989).

In their brief the Bennetts alleged that the Griffins had undertaken to repair rotten sub-flooring and their brief cites specific pages of the record; however a careful reading of the pages cited reveals no such evidence of an undertaking. Furthermore, the record contains no evidence that the Griffins had any knowledge that the house was structurally unsound.

A review of the record shows that the only evidence indicating that the Griffins were aware of any defect at all in their home was a clearance letter from the termite company that had inspected their home prior to their purchase, which noted “weather rot found on floor joist above the crawl hole.” This type of defect does not constitute evidence of structural unsoundness and does not qualify as a latent defect. The Griffins had every opportunity to inspect the crawl hole or to enter and inspect the entire crawl space.

In addition, we note that the Bennetts rely heavily on Rumford v. Valley Pest Control, Inc.,

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Related

Cornelius v. Austin
542 So. 2d 1220 (Supreme Court of Alabama, 1989)
Cato v. Lowder Realty Co.
630 So. 2d 378 (Supreme Court of Alabama, 1993)
Fennell Realty Co., Inc. v. Martin
529 So. 2d 1003 (Supreme Court of Alabama, 1988)
Ray v. Montgomery
399 So. 2d 230 (Supreme Court of Alabama, 1980)
Woodham v. Nationwide Life Ins. Co.
349 So. 2d 1110 (Supreme Court of Alabama, 1977)
Rumford v. Valley Pest Control, Inc.
629 So. 2d 623 (Supreme Court of Alabama, 1993)
Hanners v. Balfour Guthrie, Inc.
564 So. 2d 412 (Supreme Court of Alabama, 1990)
Hurst v. Alabama Power Co.
675 So. 2d 397 (Supreme Court of Alabama, 1996)
Allen v. Storie
579 So. 2d 1316 (Supreme Court of Alabama, 1991)
Berner v. Caldwell
543 So. 2d 686 (Supreme Court of Alabama, 1989)
West v. Founders Life Assur. Co. of Florida
547 So. 2d 870 (Supreme Court of Alabama, 1989)

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Bluebook (online)
701 So. 2d 1122, 1997 Ala. Civ. App. LEXIS 301, 1997 WL 174844, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bennett-v-cell-pest-control-inc-alacivapp-1997.