Bolivar Real Estate, LLC v. Rochelle Pratt & Diana Pratt

CourtCourt of Appeals of Washington
DecidedSeptember 28, 2023
Docket38967-7
StatusUnpublished

This text of Bolivar Real Estate, LLC v. Rochelle Pratt & Diana Pratt (Bolivar Real Estate, LLC v. Rochelle Pratt & Diana Pratt) 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
Bolivar Real Estate, LLC v. Rochelle Pratt & Diana Pratt, (Wash. Ct. App. 2023).

Opinion

FILED SEPTEMBER 28, 2023 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

BOLIVAR REAL ESTATE, LLC, a ) No. 38967-7-III Washington Limited Liability and ) JAMISON EASTBURG, an individual, ) ) Respondents, ) ) UNPUBLISHED OPINION v. ) ) ROCHELLE PRATT, an individual, and ) DIANA PRATT, an individual, ) ) Appellants. )

LAWRENCE-BERREY, J. — Rochelle and Diana Pratt appeal the trial court’s

summary judgment order enforcing a settlement agreement and awarding reasonable

attorney fees and costs in accordance with the agreement. The Pratts contend the trial

court erred because genuine issues of material fact exist supporting their defenses of

duress, breach of agreement, and unconscionability. We affirm the trial court and award

the respondents their reasonable attorney fees and costs on appeal.

FACTS

We set forth the facts, below, in the light most favorable to the Pratts, the party

resisting summary judgment below. No. 38967-7-III Bolivar Real Estate v. Pratt

The Pratts’ tenancy before the CR 2A agreement

Douglas and Dawn Burpee, through Bolivar Real Estate, LLC (Bolivar) owned a

property in Spokane Valley that contained a main house and a smaller cottage. The

Burpees leased the property to their son, Jamison Eastburg, who lived in the main house

and, beginning in December 2019, he subleased the cottage to Rochelle and Diana Pratt.1

Throughout their tenancy, Mr. Eastburg and the Pratts had numerous

disagreements. Rather than recount all of the various disagreements, it is sufficient to say

that as the relationship deteriorated, Mr. Eastburg engaged in repeated acts of harassment

and retaliation.

In June 2021, Rochelle injured her toe when a brick in a pile in the shared yard fell

on her foot. Due to the injury, Rochelle needed to have her toenail removed, resulting in

great pain when walking.

In August 2021, Mr. Eastburg and Bolivar served separate 90-day notices of

termination on the Pratts, informing them that Bolivar was selling the property and the

Pratts’ tenancy would terminate on November 30, 2021.

1 Because the Pratts share the same last name, we shall refer to them by their first names. We mean no disrespect.

2 No. 38967-7-III Bolivar Real Estate v. Pratt

In October 2021, the Pratts researched Mr. Eastburg and discovered he had a

previous restraining order against him.

In early November, Mr. Eastburg used his air compressor to blow the water out of

the sprinkler system, hitting Diana with the water, hurting her skin, startling her, and

causing her to jump up and hurt her knees, which had a history of injury. Diana had to go

to urgent care for her knee pain and reported the incident to the police nonemergency line.

Negotiation of the CR 2A agreement

The parties disputed the Pratts’ existing lease status. Bolivar and Mr. Eastburg2

took the position that the Pratts were on a month-to-month lease since their written one-

year lease had expired on May 31, 2021. The Pratts took the position that they had

renewed the lease, over text message, for an additional one-year term, until May 31, 2022,

and thus the notice of termination was ineffective.

Both sides negotiated through counsel beginning in early November 2021. The

Pratts repeatedly rejected Bolivar’s proposals. On November 27, counsel for the Pratts

wrote to counsel for Bolivar that Rochelle was

willing to waive any tort claims against your client for her injured foot, and would agree to end her tenancy May 31, 2022, if your client will rescind the 90[-]day notice. Your clients would of course be free to sell the home prior to May 31, subject to the tenancy.

2 For brevity, we will now refer to both collectively as “Bolivar.”

3 No. 38967-7-III Bolivar Real Estate v. Pratt

Clerk’s Papers (CP) at 208. After proposing a counteroffer, which the Pratts again

rejected, Bolivar accepted the Pratts’ offer on December 8, 2021.

The parties executed a CR 2A agreement, which provided that it “constitute[d]

the entire agreement between the Parties.” CP at 216. The agreement further provided:

1. Tenants agree that the tenancy for the Premises shall terminate on May 31, 2022 as a matter of law and that this Agreement constitutes notice of termination of the tenancy for the Premises pursuant to RCW 59.18.650. 2. Tenants specifically waive any and all claims or causes of action under the residential landlord tenants statute related to termination of a periodic and/or year tenancy. Tenants further agree that this Agreement constitutes written notice and acceptance of notice pursuant to RCW 59.18.650(5) that the tenancy is ending in order to sell the Premises pursuant to RCW 59.18.650(2)(e). 3. Tenants shall continue to pay rent and meet all other obligations imposed by the residential lease agreement until termination of the tenancy as set forth in paragraph 1. 4. Owner agrees to withdraw the previously issued 90[-]day notice of sale provided to the tenant to terminate the tenancy November 30, 2021. Owner may immediately sell the Premises. Tenants agree to allow Owner reasonable access for an appraisal, to remove the air conditioning unit, and other access to the Premises as provided in RCW Chapter 59.18 upon written notice from the Owner and/or Landlord as also provided in RCW Chapter 59.18. 5. This Agreement does not waive any remedies available to the Owner and/or Landlord related to eviction for cause as set forth in RCW 59.18.650(2)(a), (b), (c), (h), (1), (m), (n), (o), (p). 6. Tenants shall sign a separate settlement agreement releasing any claim for wrongful eviction under RCW Chapter 59.12 an RCW Chapter 59.18, any claim for tort liability for injuries allegedly sustained on the Premises, and an agreement which incorporates the provisions of this Agreement. The prevailing party in any legal proceedings to enforce the

4 No. 38967-7-III Bolivar Real Estate v. Pratt

terms of this Agreement and/or the executed settlement agreement shall be entitled to payment of all attorney fees and costs incurred.

CP at 216-17. All parties signed the CR 2A agreement on December 13, 2021. Shortly

after, Bolivar Real Estate, LLC, sold the property to Mr. Eastburg.

After various minor delays, on January 11, 2022, the Pratts’ attorney sent his

clients a copy of the proposed release agreement. The Pratts expressed concern that the

property had actually been sold on December 2, 2021, which was before the CR 2A

agreement was signed. It emerged that although the real estate excise tax affidavit was

dated either December 2 or 3, 2021, it was signed by the grantor on December 29, 2021

and the grantee on January 3, 2022. Although dated December 2, 2021, the deed was

signed and notarized on December 29 and recorded on January 4, 2022. According to the

title company, the documents had originally been prepared in early December, but the sale

had been put on hold because of ongoing negotiations between the parties.

Rochelle was not physically able to visit a notary in January, so the Pratts did not

sign the release agreement.

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