Clampitt v. A.M.R. Corp.

706 P.2d 34, 109 Idaho 145, 1985 Ida. LEXIS 530
CourtIdaho Supreme Court
DecidedMay 6, 1985
Docket15071
StatusPublished
Cited by13 cases

This text of 706 P.2d 34 (Clampitt v. A.M.R. Corp.) is published on Counsel Stack Legal Research, covering Idaho Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Clampitt v. A.M.R. Corp., 706 P.2d 34, 109 Idaho 145, 1985 Ida. LEXIS 530 (Idaho 1985).

Opinions

BAKES, Justice.

The sole issue in this appeal is whether the amounts retained by the vendor pursuant to forfeiture of a real estate purchase contract constitute an unconscionable penalty to the defaulting purchaser. We affirm the judgment of the trial court which held that the amounts forfeited under the contract bear a reasonable relation to the vendor’s actual damages and therefore do not constitute an unconscionable penalty.

A.M.R. Corporation agreed to purchase from Clampitts a 3,800-acre farm located in Elmore County, Idaho. The purchase price was $2.3 million to be paid as follows: $10,000 down at the execution of the purchase agreement in September, 1974; $250,000 in December, 1974; $250,000 in February, 1975; and the balance in semiannual payments of $89,500 each. Of the total farm acreage, 2,140 acres were under irrigation, approximately 1,400 acres were yet to be developed with water rights reserved but not yet put to beneficial use, and the balance was dry land. After executing the agreement the purchaser, A.M.R. Corporation, took possession of the farm. Vendors, Clampitts, retired from farming and moved to the State of Washington, although the vendors remained as lessees of record in a joint venture with their son during the growing season of 1975. It was purchaser’s intention to lease out the farm, develop the unirrigated portions, and eventually divide the entire farm into smaller portions to be sold at a profit. A.M.R. had previously purchased, subdivided and sold at a profit an adjoining and even larger farm.

Purchaser had difficulty in making the initial payments, and two subsequent contract amendments were executed to allow for late payments. Purchaser was unable to discharge the semiannual payments and continued negotiations were unfruitful. In September, 1976, vendors filed the initial complaint in the present action seeking a declaration of forfeiture, return of the farm, and a determination of quiet title. Purchaser counterclaimed that the amounts retained in forfeiture constitute an unconscionable penalty.

The purchaser apparently stipulated to partial summary judgment granting return of the property, judgment of forfeiture, and quiet title in favor of the vendors. At the time of the summary judgment stipula[148]*148tion there was an alleged oral settlement agreement between the parties having to do with vendors’ repossession of the property, obtaining of new financing, developing of the unirrigated portions, and possible resale of the property to purchaser. This alleged settlement agreement was reduced to writing, but purchaser refused to execute it since the terms were in dispute.

The vendors returned from Washington, took possession of the farm, and obtained new financing in excess of $2 million in order to discharge the existing indebtedness which was in default and to install a major irrigation system to apply and preserve the water rights, then due to expire unless put to beneficial use. After successfully refinancing and developing the farm, the vendors then resold the farm with the new irrigation improvements to a different purchaser for $3.8 million.

The case proceeded to trial on purchaser’s counterclaim. At the time of forfeiture purchaser had paid $510,000 in principal and $221,753.24 in interest to the vendors. Purchaser also claims consideration of other amounts paid in taxes, improvements and personal property. The trial court found that vendors’ expenses in repossessing, refinancing, and reselling the property were so “intertwined” that those expenses must be considered as damages. The trial court found vendors’ actual damages to be $305,648,1 consisting of expenses for weed eradication, sprinkler pipe repair, loan fees, attorney fees and real estate commissions for the resale. The trial court also found the reasonable rental for the property was $447,518.51 during the two years in which purchaser was in possession of the property, and that there had been no depreciation or appreciation in the value of the property during the purchaser’s possession. The court concluded that the purchaser “failed to establish, by a preponderance of the evidence, that under the facts here the payments it made on the contract were so disproportionate to the actual damages incurred by [vendors] as a result of [purchaser’s] breach as to be exorbitant amounting to an unconscionable penalty.”

The purchaser has appealed, arguing that many of the items of vendors’ damages as found by the trial court were unsupported by the evidence or improperly allowed.

The appellant, defaulting purchaser in the present case, appears to take the position that all amounts previously paid on a forfeited real estate contract constitute "unjust enrichment” to the vendor and that vendor may only retain those amounts proved by substantial evidence to be “set-offs against unjust enrichment.” This position is not consistent with our prior cases.

“ ‘Generally speaking, parties to a contract may agree on liquidated damages in anticipation of a breach, in any case where the circumstances are such that accurate determination of the damages would be difficult or impossible, and provided that the liquidated damages fixed by the contract bear a reasonable relation to actual damages. But, where the forfeiture or damage fixed by the contract is arbitrary and bears no reasonable relation to the anticipated damage, and is exorbitant and unconscionable, it is regarded as a “penalty”, and the contractual provision therefore is void and unenforceable.’ Graves v. Cupic, 75 Idaho 451, 456, 272 P.2d 1020, 1023 [1954].
“... In seeking relief from the forfeiture, the burden of proving such facts rested upon [the defaulting purchasers].” Howard v. Bar Bell Land & Cattle Co., 81 Idaho 189, 197, 340 P.2d 103, 107 (1959).

Further, “it is for the trial court to determine under the facts of any particular case whether the amount stipulated as damages bears such reasonable relation to the damages actually sustained as to be enforceable as a provision for liquidated damages.” Nichols v. Knowles, 87 Idaho 550, [149]*149556, 394 P.2d 630, 633 (1964). The finding of the trial court as to whether the forfeiture and liquidated damages constitute an unconscionable penalty will not be overturned on appeal unless it is clearly erroneous. I.R.C.P. 52(a).

In the present case the purchaser voluntarily agreed in the purchase contract that in the event of purchaser's default the vendor had the remedy of retaining all amounts paid, and that purchaser would forfeit all interest in the property to the vendors. Thus the purchaser had the burden of proof at trial to show that these liquidated damages bore no reasonable relation to the actual damages. Howard v. Bar Bell Land & Cattle Co., supra.

I

Liquidated Damages

At the time of forfeiture, purchaser had paid $510,000 in principal and $221,753 in interest on the purchase contract. Purchaser had also paid the amount of $7,338 toward an irrigation mainline which the seller repossessed with the property. Purchaser had also paid $13,783 for the 1975 property taxes which “was part of [the] contract obligation, the same as [the] payments upon the principal balance,” Anderson v. Michel,

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706 P.2d 34 (Idaho Supreme Court, 1985)

Cite This Page — Counsel Stack

Bluebook (online)
706 P.2d 34, 109 Idaho 145, 1985 Ida. LEXIS 530, Counsel Stack Legal Research, https://law.counselstack.com/opinion/clampitt-v-amr-corp-idaho-1985.