Ferro v. Merritt CA2/4

CourtCalifornia Court of Appeal
DecidedJanuary 29, 2025
DocketB330902
StatusUnpublished

This text of Ferro v. Merritt CA2/4 (Ferro v. Merritt CA2/4) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ferro v. Merritt CA2/4, (Cal. Ct. App. 2025).

Opinion

Filed 1/29/25 Ferro v. Merritt CA2/4

NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA SECOND APPELLATE DISTRICT DIVISION FOUR

CARL FERRO, B330902

Plaintiff and Respondent, (Los Angeles County Super. Ct. No.20STCV36194) v.

WILLIAM MERRITT,

Defendant and Appellant.

APPEAL from a judgment of the Superior Court of Los Angeles County, Gail Killefer and Richard J. Burdge, Jr., Judges. Affirmed in part, reversed in part and remanded. Pamela A. Mozer for Defendant and Appellant. Friedman, Enriquez & Carlson, Grant A. Carlson for Plaintiff and Respondent. Plaintiff Carl Ferro (buyer) sued defendant William Merritt (seller) for breach of contract arising out of a purchase agreement (the PSA) for the sale of residential property. Buyer alleged that under the PSA, it was seller’s obligation to deliver the property free from tenants five days prior to the close of escrow. However, as of closing, the property was occupied by seller’s business associate, John Mizerak. Seller contends that buyer waived his right to enforce this term of the PSA when buyer signed amended escrow instructions waiving all contingencies and closing escrow knowing the tenant remained in the property. Following a bench trial, the court entered judgment in favor of buyer. The court found that the PSA was ambiguous and that the intent and conduct of the parties established their agreement that it was seller’s obligation to remove Mizerak from the property. The court further found that even if buyer had waived this term, he did not do so knowingly. The court awarded buyer the damages arising from the delay in his ability to move into the property and the attorney fees he paid to evict Mizerak. On appeal, seller argues that the evidence supported the conclusion that the provision regarding removing tenants was a contingency, which buyer knowingly waived. Seller also challenges the damages award, arguing that buyer failed to mitigate his damages and that the delays in eviction caused by the COVID-19 pandemic were not foreseeable at the time the parties entered into the PSA. We agree that the court erred in finding that buyer was entitled to damages arising from pandemic-related delays and reverse that portion of the damages award. We otherwise find no error and affirm the remainder of the judgment. FACTUAL AND PROCEDURAL BACKGROUND I. The Complaint Buyer filed a complaint against seller in September 2020, alleging claims for breach of contract and rescission. Buyer alleged that in October 2019, he and seller entered into the PSA, a written purchase agreement regarding a residential property on Wilkinson Avenue (the property). Buyer further alleged that at the time of the purchase Mizerak was staying at the property with seller’s permission. Under the PSA, seller agreed that the property would be vacant at least five days prior to the close of escrow.

2 The complaint further alleged that seller made efforts to evict Mizerak from the property, including serving a 60-day notice to vacate the property in December 2019 and then a 30-day notice to quit in January 2020. However, Mizerak refused to vacate the property and continued to live there as of the date of the complaint. Thus, buyer contended that seller breached the purchase agreement by failing to deliver possession. The complaint sought monetary damages and rescission of the PSA.1 II. Trial The matter proceeded to a court trial in December 2022. The parties stipulated to the admission of exhibits, including all of the documents detailed herein. The following relevant evidence was adduced at trial. A. The PSA The PSA, a modified form agreement issued by the California Association of Realtors (C.A.R.), indicates that it was prepared in October 2019. The paragraphs of the PSA addressing real estate agents and brokers were crossed out. The parties relied on several provisions of the PSA at trial. Crucially, paragraph 9, titled “CLOSING AND POSSESSION,” section D provides, “Tenant-occupied property: Property shall be vacant at least 5 . . . Days Prior to Close of Escrow, unless otherwise agreed in writing. Note to Seller, if you are unable to deliver Property vacant in accordance with rent control and other applicable Law, you may be in breach of this Agreement.” Paragraph 11, titled “CONDITION OF PROPERTY,” states that “[U]nless otherwise agreed in writing: (i) the Property is sold (a) ‘AS-IS’ in its PRESENT physical condition as of the date of Acceptance and (b) subject to Buyer’s investigation rights.” Paragraph 12, section A provides “Buyer’s acceptance of the condition of, and any other matter affecting the Property, is a contingency of this Agreement as specified in this paragraph and paragraph 14B.” Paragraph 12, section B (paragraph 12B) requires seller to make the property available for buyer’s investigation and requires buyer to “complete Buyer investigations and either remove the contingency or cancel this agreement.”

1 By the time of trial, Mizerak had been evicted from the property and buyer sought only monetary damages. 3 Pursuant to paragraph 14, section A (paragraph 14A), seller must deliver within seven days of acceptance of the PSA “all Reports, disclosures, and information for which Seller is responsible under paragraphs 5, 6, 7, 8B(5), 10A, D, C, and F, 11A and 13A.” If seller fails to do so, buyer may cancel the agreement “after first Delivering to Seller a Notice to Seller to Perform.” Section B specifies the time for buyer to complete all investigations and review of information, request action from seller, and remove the applicable contingency or cancel the agreement. Section F (paragraph 14F) deals with the removal of contingencies, stating that if “Buyer removes, in writing, any contingency or cancellation rights, unless otherwise specified in writing, Buyer shall conclusively be seemed to have (1) completed all Buyer Investigations, . . . (ii) elected to proceed with the transaction, and (iii) assumed all liability, responsibility and expense for Repairs or corrections pertaining to that contingency or cancellation right, or for the inability to obtain financing.” The PSA also contained the following integration provision: “All understandings between the Parties are incorporated in this Agreement. Its terms are intended by the Parties as a final, complete and exclusive expression of their Agreement with respect to its subject matter, and may not be contradicted by evidence of any prior agreement or contemporaneous oral agreement.” The parties signed amended escrow instructions on January 13, 2020, agreeing to a new escrow closing date of January 15, 2020. The amended instructions provided that buyer and seller “acknowledge full satisfaction and/or waiver of all contingencies to the close of escrow, and hereby authorize Escrow Holder to close the escrow.” B. Seller’s Testimony Seller testified that he bought the property in 2010. Mizerak stayed as a “guest” at the property for about four years, starting in 2016. During this time, seller and Mizerak were working to develop a business based on a software application involving food delivery. Seller did not charge Mizerak rent. When seller decided to sell the property in 2019, Mizerak helped list and show the property to potential buyers, including buyer Ferro. Mizerak

4 was a realtor in another state but he was not licensed in California. Seller had agreed to pay Mizerak a commission for the work he was doing for the sale. Mizerak also prepared the PSA.

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