Clallam Title And Escrow, V Patricia A. Pronesti

CourtCourt of Appeals of Washington
DecidedSeptember 12, 2023
Docket57169-2
StatusUnpublished

This text of Clallam Title And Escrow, V Patricia A. Pronesti (Clallam Title And Escrow, V Patricia A. Pronesti) 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
Clallam Title And Escrow, V Patricia A. Pronesti, (Wash. Ct. App. 2023).

Opinion

Filed Washington State Court of Appeals Division Two

September 12, 2023

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II CLALLAM TITLE AND ESCROW, No. 57169-2-II

Interpleader Plaintiff,

v.

PATRICIA ANNE PRONESTI,

Appellant, UNPUBLISHED OPINION KYLE FRITZ,

Respondent.

LEE, J. — Clallam Title and Escrow (Clallam Title) filed an interpleader action against

Patricia A. Pronesti and Kyle Fritz. Pronesti appeals the trial court’s order directing that

interpleader funds be released to Fritz following a directed verdict for Fritz. Pronesti argues that

the trial court erred by granting a directed verdict for Fritz. Both Pronesti and Fritz request attorney

fees on appeal.

We hold that the trial court erred by granting a directed verdict for Fritz. Accordingly, we

reverse the trial court’s order directing that interpleader funds be released to Fritz and remand for

a new trial. We also deny Pronesti’s and Fritz’s requests for attorney fees on appeal. No. 57169-2-II

FACTS

A. PURCHASE AND SALE AGREEMENT AND RESCISSION

Pronesti and Fritz entered into a one-page purchase and sale agreement (PSA) wherein

Fritz agreed to purchase a piece of property from Pronesti. The PSA required Fritz to pay a

$5,000.00 earnest money deposit. The PSA also included a rescission clause stating that Fritz

shall have 72 hours from the date of receipt of a current Title Report to determine its suitability to Buyer, at Buyer[’]s sole discretion. If prior to the end of the 72 hour Period, Buyer notifies Seller that the Title is not suitable to Buyer, Earnest Money shall be returned to Buyer and this transaction shall be rescinded.

Clerk’s Papers at 121. The PSA provided that defaulting on the agreement would result in

forfeiture of the earnest money. The PSA listed Clallam Title as the closing agent for the

transaction and stated that Pronesti authorized the closing agent to apply for title insurance paid

for by Pronesti.

On the same day that Pronesti and Fritz entered into the PSA, Pronesti provided Fritz with

a title report from Olympic Title. The Olympic Title report that Pronesti provided was not prepared

for Fritz, but for a third party who was not a part of the transaction between Pronesti and Fritz.

Fritz deposited the $5,000.00 earnest money the day after signing the PSA. Several days

later, Clallam Title provided a title report to Fritz’s representative and stated that it would also

provide the title report to Fritz. Fritz emailed Pronesti and rescinded his offer within 72 hours of

receiving the title report from Clallam Title, but more than 72 hours after receiving the title report

from Olympic Title.

2 No. 57169-2-II

B. INTERPLEADER ACTION

Clallam Title filed an interpleader complaint against Pronesti and Fritz to resolve the

conflicting claims to the earnest money. The case proceeded to a bench trial.

Fritz’s attorney submitted a trial memorandum prior to the bench trial. Pronesti, who

appeared pro se, did not submit a trial memorandum. Pronesti asked at the beginning of the trial

if the trial court wanted her to present her evidence. The trial court stated that they would wait

until later for Pronesti to present her evidence, which would be presented “in the ordinary course.”

Verbatim Rep. of Proc. (VRP) at 7.

The trial court invited Fritz to testify first. Fritz testified that he rescinded his offer based

on the title report he received from Clallam Title. The trial court allowed Pronesti to cross-examine

Fritz, and Fritz testified on cross-examination that he did not want to use the title report from

Olympic Title and did not look at the report from Olympic Title. During Fritz’s testimony, the

trial court admitted as evidence the PSA and several emails between the parties.1

After Fritz’s testimony, Fritz’s attorney orally moved for a directed verdict “based on the

exhibits” because they believed “there’s not much at issue here.” VRP at 27. The trial court stated

that there was nothing at issue and it was a simple case. Pronesti attempted to speak to the trial

1 The admitted emails include: (1) Pronesti’s email to Fritz on November 4 with the title report from Olympic Title; (2) an email from Clallam Title on November 8, stating that the company had received Fritz’s earnest money and listing the next step of the process as completing a title report; (3) an email from Clallam Title confirming that Fritz’s real estate broker or lender received a title report from Clallam Title on November 9; and (4) Fritz’s email to Pronesti rescinding his offer on November 11.

3 No. 57169-2-II

court and said “I would like to. . .,” but the trial court interrupted Pronesti and told her to not

interrupt. VRP at 28.

The trial court granted a directed verdict in favor of Fritz. The trial court ruled that because

Fritz rescinded his offer within 72 hours of receiving the title report from Clallam Title, he was

entitled to recover his earnest money.

Pronesti asked the trial court if she had the right to call witnesses, to which the trial court

responded that nothing could be gained by her calling witnesses and that it did not need her

evidence to make a decision in the case. The trial court entered an order directing that the earnest

money be released to Fritz.

Pronesti moved for reconsideration, asserting an irregularity in the proceedings, a ruling

contrary to law because the trial court did not allow her to present her side of the case, and

insufficient evidence to justify the trial court’s verdict against her. The trial court denied Pronesti’s

motion for reconsideration.

Pronesti appeals.

ANALYSIS

A. DIRECTED VERDICT

Pronesti argues that the trial court erred by granting a directed verdict for Fritz. We agree.

Directed verdicts are governed by CR 50, which refers to directed verdicts as judgments as

a matter of law. Mancini v. City of Tacoma, 196 Wn.2d 864, 876-77, 479 P.3d 656 (2021); Guijosa

v. Wal-Mart Stores, Inc., 144 Wn.2d 907, 915, 32 P.3d 250 (2001); see CR 50. We review a trial

court’s grant of a directed verdict de novo. Paetsch v. Spokane Dermatology Clinic, P.S., 182

4 No. 57169-2-II

Wn.2d 842, 848, 348 P.3d 389 (2015). We construe all facts in the light most favorable to the

nonmoving party (here, Pronesti). Id.

CR 50(a)(1) provides that

[i]f, during a trial by jury, a party has been fully heard with respect to an issue and there is no legally sufficient evidentiary basis for a reasonable jury to find or have found for that party with respect to that issue, the court may grant a motion for judgment as a matter of law against the party on any claim, counterclaim, cross claim, or third party claim that cannot under the controlling law be maintained without a favorable finding on that issue. Such a motion shall specify the judgment sought and the law and the facts on which the moving party is entitled to the judgment.

Here, the trial court granted the directed verdict at a bench trial, but CR 50’s plain language

limits the rule’s applicability to jury trials. Further, CR 50(a)(1) requires motions for directed

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Related

Korst v. McMahon
148 P.3d 1081 (Court of Appeals of Washington, 2006)
Guijosa v. Wal-Mart Stores, Inc.
32 P.3d 250 (Washington Supreme Court, 2001)
Mancini v. City Of Tacoma
479 P.3d 656 (Washington Supreme Court, 2021)
Guijosa v. Wal-Mart Stores, Inc.
144 Wash. 2d 907 (Washington Supreme Court, 2001)
Paetsch v. Spokane Dermatology Clinic, PS
348 P.3d 389 (Washington Supreme Court, 2015)
Korst v. McMahon
136 Wash. App. 202 (Court of Appeals of Washington, 2006)
Stiles v. Kearney
277 P.3d 9 (Court of Appeals of Washington, 2012)

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Bluebook (online)
Clallam Title And Escrow, V Patricia A. Pronesti, Counsel Stack Legal Research, https://law.counselstack.com/opinion/clallam-title-and-escrow-v-patricia-a-pronesti-washctapp-2023.