CPL, L.L.C. v. Conley

110 Wash. App. 786
CourtCourt of Appeals of Washington
DecidedFebruary 15, 2002
DocketNo. 27199-1-II
StatusPublished
Cited by8 cases

This text of 110 Wash. App. 786 (CPL, L.L.C. v. Conley) 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
CPL, L.L.C. v. Conley, 110 Wash. App. 786 (Wash. Ct. App. 2002).

Opinion

Seinfeld, J.

— The trial court resolved this dispute between Quad C Health Care Centers, the seller of nursing facilities, and CPL (Delaware) LLC, the purchaser of those facilities, by granting summary judgment to Quad C. Finding no disputed issues of material fact, we affirm. We also affirm the trial court’s denial of Quad C’s request for attorney fees.

FACTS

In April 1998, CPL entered into purchase agreements to buy skilled nursing facilities from Quad C.1 CPL agreed to pay $48 million for the facilities plus an additional “earnout payment,” contingent on 1998 earnings meeting a certain target level. The parties developed a formula to calculate earnings before interest, taxes, depreciation, amortization, rent and central office charges (EBITDAR).

To calculate the EBITDAR, Quad C provided financial statements for the facilities from January 1, 1998, to the July 1, 1998, closing date; CPL did the same after closing. In late March 1999, the parties signed a Memorandum Agreement under which CPL agreed to pay a $2,017,468 earnout payment on or before April 1, 1999.

About three months after the payment date, CPL notified Quad C that it had discovered “computational and arithmetic errors” resulting in an incorrect EBITDAR calculation. 2 Clerk’s Papers (CP) at 302. Claiming that Quad C was not entitled to an earnout payment, CPL demanded a refund of the timely payment that it had made.

Quad C responded:

In March 1999, the parties calculated the Earnout Payment, [790]*790negotiated an agreement on the amount of this payment, and entered into a Memorandum Agreement acknowledging both the amount of the payment and that the parties had no further obligation between them with respect to the Earnout Amount. Relying on that memorandum agreement, Quad-C distributed proceeds of the Earnout Payment to others involved in the transfer of the Quad-C facilities, pursuant to its agreements with these individuals.

2 CP at 304. Quad C claimed that the Memorandum Agreement was an accord and satisfaction and it refused to refund CPL’s payment.

CPL sued to obtain a $1,993,360 refund. In its complaint, CPL alleged that the overpayment was the result of a mutual mistake as to the facilities’ earnings, that Quad C had fraudulently or negligently withheld facts from CPL, and that Quad C had acted inequitably. After Quad C moved for summary judgment, CPL asked the court to compel arbitration of the EBITDAR calculation pursuant to the parties’ purchase agreements.

The trial court denied CPL’s motion to compel arbitration, granted Quad C’s summary judgment motion, and denied Quad C’s later request for attorney fees. CPL appeals the summary judgment order and the denial of its motion to compel arbitration. Quad C cross-appeals the court’s denial of its request for attorney fees.

ANALYSIS

I. Alleged Overpayment

Summary judgment is appropriate if the evidence, viewed in the nonmoving party’s favor, shows that there is no genuine issue of material fact and that the moving party is entitled to judgment as a matter of law. CR 56(c); Schaaf v. Highfield, 127 Wn.2d 17, 21, 896 P.2d 665 (1995). A material issue of fact is one upon which the litigation’s outcome depends. Capitol Hill Methodist Church v. City of Seattle, 52 Wn.2d 359, 364, 324 P.2d 1113 (1958). The court [791]*791should grant the motion if reasonable persons could reach only one conclusion. Wilson v. Steinbach, 98 Wn.2d 434, 437, 656 P.2d 1030 (1982).

A. Mutual Mistake and Assumption of the Risk

CPL asserts that the parties were mutually mistaken about the correct EBITDAR figure and that this figure was an essential fact in the formation of the Memorandum Agreement. Quad C responds that the Memorandum Agreement represents an accord and satisfaction of disputed issues, including the EBITDAR calculation and, further, even if there was a mutual mistake, CPL is not entitled to relief because it assumed the risk of that mistake.

“A contract is voidable on grounds of mutual mistake when both parties independently make a mistake at the time the contract is made as to a basic assumption of the contract, unless the party seeking avoidance bears the risk of the mistake.” Bennett v. Shinoda Floral, Inc., 108 Wn.2d 386, 396, 739 P.2d 648 (1987). See also Restatement (Second) of Contracts § 151 (1981) (“A mistake is a belief that is not in accord with the facts.”). In the contractual setting, a party bears the risk of a mistake if “ ‘he is aware, at the time the contract is made, that he has only limited knowledge with respect to the facts to which the mistake relates but treats his limited knowledge as sufficient.’ ” Bennett, 108 Wn.2d at 396 (quoting Restatement (Second) of Contracts § 154(b) (1981)).2 In other words, a party’s willingness to enter a contract notwithstanding limited knowledge of certain facts shows that those facts were not essential elements of the contract. Bennett, 108 Wn.2d at 396 (“In such a situation there is no mistake. Instead, there [792]*792is an awareness of uncertainty or conscious ignorance of the future.”).

Here, Exhibit 2.03 to the purchase agreements outlined the earnout payment calculations. It provided that CPL would provide Quad C with “monthly, quarterly and year-end Financial Statements no later than five business days after such Financial Statements are completed by [the] Purchaser.” 1 CP at 9. CPL provided that information but later discovered errors in the financial information it was responsible for producing. But there is undisputed evidence that CPL knew that it could not balance its financial statements during the period it was responsible for producing the reports. This evidence supports Quad C’s contention that CPL should have known that its financial information was unreliable.3

CPL disclaims knowledge of the financial imbalances, arguing that Quad C managers and upper level staff also were involved in the facilities’ operations even after closing. But primarily it argues that it did not have knowledge of a material risk at the time it signed the Memorandum Agreement.

Where one party has a contractual duty to provide financial statements, is aware of deficiencies in its financial information, and nonetheless chooses to act on that information, we see no basis to relieve it from assuming the risk of error because it anticipated only a small discrepancy in the numbers. Clearly, CPL was aware of the size of the consequences that could flow from an error and was aware of the uncertainties. Further, we do not see how any involvement that Quad C might have had in the operation [793]*793of the facilities after the July 1 closing date is relevant to our assumption of the risk analysis.

Finally, the cases that CPL cites are not persuasive. For example, Simonson v. Fendell, 101 Wn.2d 88, 675 P.2d 1218

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110 Wash. App. 786, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cpl-llc-v-conley-washctapp-2002.