Foster v. Wintergreen Real Estate Co.

81 Va. Cir. 353
CourtNelson County Circuit Court
DecidedNovember 16, 2010
DocketCase No. CL09000086
StatusPublished
Cited by1 cases

This text of 81 Va. Cir. 353 (Foster v. Wintergreen Real Estate Co.) is published on Counsel Stack Legal Research, covering Nelson County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Foster v. Wintergreen Real Estate Co., 81 Va. Cir. 353 (Va. Super. Ct. 2010).

Opinion

By Judge J. Michael Gamble

I am writing to rule on the demurrer and motion to dismiss of the defendants. My rulings will follow the same order as the arguments in support of the demurrer and motion to dismiss set forth in the opening memorandum of the defendants.

General Matters

The function of a demurrer is well settled. It tests whether the complaint states a cause of action upon which relief can be granted. Shelor Motor Co. v. Miller, 261 Va. 473, 478, 544 S.E.2d 345, 348 (2001). Further, the demurrer admits the truth of all properly pleaded material facts and all reasonable inferences fairly and justly drawn from the facts. The demurrer does not admit the correctness of conclusions of law pleaded. Dodge v. Trustees of Randolph-Macon Woman’s College, 276 Va. 1, 5, 661 S.E.2d 801, 803 (2008).

A court may also consider the contents of documents that are a part of the pleading or mentioned in the pleading and produced pursuant to a motion craving oyer. Smith v. Chesterfield Meadows Shopping Ctr. Assocs., L.P., 259 Va. 82, 85, 523 S.E.2d 834, 835 (2000); Ward’s Equipment, Inc. v. New Holland North Am., Inc., 254 Va. 379, 382-83, 493 S.E.2d 516, 518 (1997).

Economic Loss Doctrine

The Supreme Court of Virginia has issued a series of decisions holding that a litigant cannot assert tort claims that arise out of contractual duties. See most recently Station # 2, L.L.C. v. Lynch, 280 Va. 166, 695 S.E.2d 537 (2010). In their demurrer the defendants argue that the claims of the plaintiff for fraud in the inducement under Count I, negligent breach of professional duties under Count II, breach of fiduciary duty under Count III, statutory conspiracy under Count VI, common law conspiracy under Count VII, and tortious interference under Count IX must be dismissed because they are tort claims that arise out of contract. The rule under which tort claims are barred when a cause of action arises out of contract is commonly called the economic loss doctrine. See Abi-Najm v. Concord Condominium, L.L.C., 280 Va. 350, 699 S.E.2d 483 (2010). In order to determine whether the economic loss doctrine applies, a court must first determine “whether a cause of action sounds in contract or tort.” Richmond Metro. Auth. v. McDevitt Street Bovis, Inc., 256 Va. 553, 558, 507 S.E.2d 344, 347 (1998).

Tort law provides a remedy for common law and statutory duties involving the safety of persons and property which are imposed to protect the broad interests of society. Filak v. George, 267 Va. 612, 618, 594 [355]*355S.E.2d 610, 613 (2004). Accordingly, damages resulting from a breach of duty created by agreement, rather than a duty imposed by law, can only be recovered pursuant to contract law rather than tort law. Abi-Najm, 699 S.E.2d at 489; Filak, 267 Va. at 618, 594 S.E.2d at 613.

Even though the economic loss doctrine prohibits tort claims arising out of a contractual relationship, an act or occurrence can, under certain circumstances, support causes of action for both contract and tort. Dunn Constr. Co. v. Cloney, 278 Va. 260, 266-67, 682 S.E.2d 943, 946 (2009); Foreign Mission Bd. v. Wade, 242 Va. 234, 241, 409 S.E.2d 144, 148 (1991). Generally, however, an action in fraud must plead a misrepresentation of present pre-existing facts and cannot be predicated on unfulfilled promises or statements as to future events. Lloyd v. Smith, 150 Va. 132, 145, 142 S.E. 363, 365 (1928). Due to this general rule, most breaches of contract cannot be made a basis for an action in fraud because the breach of contract does not occur at a time that the alleged misrepresentation of pre-existing facts occur. Boykin v. Hermitage Realty, 234 Va. 26, 29, 360 S.E.2d 177, 178 (1987). Notwithstanding the general rule, however, an action in tort for deceit and fraud may sometimes be predicated on promises which are made with a present intention not to perform them. Boykin, 234 Va. at 29, 360 S.E.2d at 178. See also, Abi-Najm, supra.

The allegations in paragraphs 17, 20, 21, 23, 24, 25, 27, 29, and 33 in the amended complaint are sufficient allegations of misrepresented facts that would induce the plaintiffs to purchase and sell real estate through the defendants’ firm together with the intention not to perform the representations at the time they were made. Accordingly, the court finds that the allegations in the amended complaint are sufficient to overcome the demurrer to fraud in the inducement on the basis of the economic loss doctrine.

Defendants further argue that the demurrer to Count II, Breach of Professional Duties, should also be sustained on the basis of the economic loss doctrine.

In Count II, the plaintiffs pleaded an action for negligent breach of the standard of care by a real estate professional. The plaintiffs assert that the defendants owed duties to the plaintiffs under “the standard of care prevailing in the locale,” under the realtor code of ethics, and under the regulations of the Virginia Real Estate Board. The plaintiffs make no allegation of a breach of professional duties under Va. Code § 54.1-2130 et seq. In particular, Va. Code §§ 54.1-2130, 54.1-2131, 54.1-2132, and 54.1- 2144 set forth the statutory duties of real estate professionals that are incorporated into each contract for the purchase or sale of real estate. Section 54.1- 2131 sets forth the duties of agents representing sellers, and § 54.1-2132 sets forth the duties of agents representing buyers. Both incorporate the definition of “brokerage relationship,” which is defined under Va. Code § 54.1-2130 as a contractual relationship between the client and real estate [356]*356professional. Further, Va. Code § 54.1-2144 abrogates the common law of agency relative to brokerage relationships in real estate transactions.

Thus, this court must conclude that the duties between a real estate professional and a client are defined by the Code of Virginia and incorporated into each contractual relationship. This was touched on by the Supreme Court of Virginia in Polyzos v. Cotrupi, 264 Va. 116, 563 S.E.2d 775 (2002). There, the court noted that Va. Code § 54.1-2131 requires realtors to “perform in accordance with the terms of the brokerage relationship” and “exercise ordinary care.” Polyzos, 264 Va. at 122, 563 S.E.2d at 778. As noted above, Va. Code § 54.1-2130 defines a “brokerage relationship” as a contractual relationship. Accordingly, any duty to “exercise ordinary care” must arise out of the contractual relationship. The plaintiffs have not stated a cause of action under Count II for a tort action based upon a failure of the real estate professionals to exercise ordinary case.

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Bluebook (online)
81 Va. Cir. 353, Counsel Stack Legal Research, https://law.counselstack.com/opinion/foster-v-wintergreen-real-estate-co-vaccnelson-2010.