Eric Frye v. The Estate of Marvyn Raphaelson

CourtCourt of Chancery of Delaware
DecidedAugust 31, 2023
DocketC.A. No. 2020-0325-SEM
StatusPublished

This text of Eric Frye v. The Estate of Marvyn Raphaelson (Eric Frye v. The Estate of Marvyn Raphaelson) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Eric Frye v. The Estate of Marvyn Raphaelson, (Del. Ct. App. 2023).

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

ERIC FRYE, ) ) Petitioner, ) ) v. ) C.A. No. 2020-0325-SEM ) THE ESTATE OF MARVYN ) RAPHAELSON, ) ) Respondent. ) ) THE ESTATE OF MARVYN ) RAPHAELSON, ) ) Counterclaim Plaintiff, ) ) v. ) ) ERIC FRYE, ) ) Counterclaim Defendant. )

Draft Report: August 31, 2023 Date Submitted: April 24, 2023

FINAL POST-TRIAL REPORT

Donald L. Gouge, Jr., DONALD L. GOUGE, JR. LLC, Wilmington, DE; Plaintiff’s attorney

Charles J. Brown, GELLERT SCALI BUSENKELL & BROWN, LLC, Wilmington, DE; Defendant’s attorney Pending before me are competing claims of unjust enrichment arising from

the use and maintenance (or lack thereof) of real property. The property owner

contends the occupant failed to pay rent or properly maintain the property, which

inured to the occupant’s benefit, while detrimentally affecting the owner’s interests.

The property owner further contends the occupant wrongfully remained on the

property after the owner told the occupant to vacate, amounting to trespass. The

occupant disagrees that any rent was owed and, rather, contends he made substantial

improvements to the property that have enriched the owner to the occupant’s

detriment. The occupant further contends he made payments toward the ultimate

purchase of the property and should be compensated for the failed transaction. He

also denies that his continued use and occupancy of the property supports a finding

of trespass; even if it did, he argues there was no damage therefrom.

In this post-trial ruling, I recommend that judgment be awarded to the owner

and against the occupant. I find that the use-and-occupancy relationship was

informal and only expressly contemplated rent for one parcel. The other parcels were

used in exchange for maintenance. I find equity does not compel payment for rent

never contemplated, nor reimbursement for maintenance expressly contemplated.

But the equities shifted once the owner revoked the permission granted to the

occupant, and the occupant’s continued use and occupancy (although not trespass)

unjustly enriched the occupant to the owner’s detriment. To rebalance the equities,

1 I recommend judgment against the occupant and in favor of the owner in the amount

of $44,000.00.

I. BACKGROUND1

The property owner in this action was Marvyn Raphaelson. Mr. Raphaelson

passed during the pendency of this action, and his estate (the “Defendant”) has been

substituted in his place.2 Eric Frye (the “Plaintiff”) was Mr. Raphaelson’s friend and

occupant at various properties in Wilmington, Delaware. I begin with their historical

relationship, building up to the dispute before me.

A. The Early Years

The Plaintiff first became familiar with Mr. Raphaelson and Mr. Raphaelson’s

business and properties when the Plaintiff was just a child.3 After finishing the tenth

grade, the Plaintiff went to work at his family’s automotive parts business,

Continental Auto S&S, Salvage and Sales.4 Mr. Raphaelson was in a similar line of

1 The facts in this report reflect my findings based on the record developed at trial on December 14, 2022. See Docket Item (“D.I.”) 70. I grant the evidence the weight and credibility I find it deserves. Citations to the trial transcript are in the form “Tr. #.” The parties’ jointly submitted exhibits are cited as “JX __.” 2 Mr. Raphaelson’s brother, Bernard Raphaelson, was also named as a defendant. D.I. 1. But he was already deceased when this action was initiated and was removed from the case before trial. See D.I. 69. 3 Tr. 9:10–11. 4 Tr. 6:15–7:4. 2 work: salvage and recycling. Thus, while working at his family’s business, the

Plaintiff would take recyclable items to Mr. Raphaelson’s business.5

But the Plaintiff and Mr. Raphaelson did not grow close until much later in

their lives. It was the Plaintiff’s decision, in his forties, to enter Mr. Raphaelson’s

line of work that brought them back together. The Plaintiff worked within the

automotive business “for most of [his] life[.]”6 But when he reached his forties, the

Plaintiff “got into heavier trucks, and then [he] went into . . . the salvage/recycling

business.”7

The Plaintiff’s new business venture started in earnest in 2004 or 2006. At

that time, he and his business partner turned to Mr. Raphaelson. Both partners were

familiar with Mr. Raphaelson—the Plaintiff from his family’s prior business with

Mr. Raphaelson, and his partner from a longstanding personal friendship with Mr.

Raphaelson. As the Plaintiff explained it, Mr. Raphaelson “was very close to [the

Plaintiff’s] partner, Joe, for years, maybe 40 years.”8 With these connections, Mr.

Raphaelson “showed [the Plaintiff and his partner] the ropes and basically put [them]

in business.”9

5 Tr. 9:8–20. 6 Tr. 7:10–12, 23–24. 7 Tr. 7:24–8:2. 8 Tr. 10:16–17. 9 Tr. 10:14–16. 3 That support included Mr. Raphaelson’s renting property to the Plaintiff and

his partner. The property was Mr. Raphaelson’s existing salvage yard at 20

Commerce Street in Wilmington, Delaware (the “Scrapyard”).10 The Scrapyard was

a relatively large, industrial flat lot with a warehouse and an office.11

In 2004 or 2006, the Plaintiff and his partner took an interest in the Scrapyard.

They installed “a brand-new scale . . . because the other scale was gone[,]” and

cleaned up the debris left from a prior tenant of Mr. Raphaelson.12 They then rented

the Scrapyard from Mr. Raphaelson until 2008 or 2009.13 Every month Mr.

Raphaelson would stop by and pick up the agreed-upon rent: $4,500.00.14

For reasons unknown, the Plaintiff and his partner left the Scrapyard and

moved their business to a location on New Castle Avenue in 2008 or 2009.15 But,

10 Tr. 8:10. The Scrapyard had a long history before the Plaintiff entered the scene. As the Plaintiff explained it, starting in the 1890s, the adjacent refinery would provide the Raphaelson family with scraps that the refinery did not want. Tr. 16:23–17:2. The Raphaelsons “would scrap and make money; and what they couldn’t get, they would either bury, pile it up, or find someplace to put it out of the way.” Tr. 17:3–5. After this historical family use, Mr. Raphaelson began renting the Scrapyard. See Tr. 14:6–7. 11 Tr. 12:13–24, 111:10–15. The Plaintiff estimates the building at the Scrapyard was 80 feet by 50 feet. Tr. 13:1–4. 12 Tr. 13:13–20. Per the Plaintiff, the prior tenant “left a huge mess[,]” and had to be evicted. Tr. 14:4–7. 13 Tr. 10:3–10. 14 Tr. 12:8–12. 15 It is unclear when, precisely, this move occurred. Compare Tr. 8:14–17 (Plaintiff) (testifying that the New Castle Avenue business was not until 2012 or 2013) with Tr. 17:19–20 (Plaintiff) (“So after we left Commerce Street, we moved to New Castle 4 with them gone, problems arose at the Scrapyard. “People started knocking the gates

down, they would dump all over Commerce Street[.]”16 The same started happening

at Mr. Raphaelson’s property across the street at 110 Dock Street.17

The Plaintiff did not use 110 Dock Street while he and his partner rented the

Scrapyard. But 100 Dock Street and 110 Dock Street (together, the “Dock Street

Properties”) were also owned by Mr. Raphaelson and located “[d]irectly across the

street” from the Scrapyard.18 The Dock Street Properties were much smaller than

the Scrapyard, by a factor of three or four, and included a smaller building than the

Scrapyard.19 But, at least at some point in time, the Dock Street Properties handled

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Bluebook (online)
Eric Frye v. The Estate of Marvyn Raphaelson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eric-frye-v-the-estate-of-marvyn-raphaelson-delch-2023.