Georgia Lay v. Todd Destafino

CourtSupreme Court of Alabama
DecidedFebruary 17, 2023
Docket1210383
StatusPublished

This text of Georgia Lay v. Todd Destafino (Georgia Lay v. Todd Destafino) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Georgia Lay v. Todd Destafino, (Ala. 2023).

Opinion

Rel: February 17, 2023

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is printed in Southern Reporter.

SUPREME COURT OF ALABAMA OCTOBER TERM, 2022-2023

_________________________

1210383 _________________________

Georgia Lay

v.

Todd Destafino

Appeal from Shelby Circuit Court (CV-19-900158)

PER CURIAM.

This case arises out of a protracted feud between two ex-relatives.

In short, Todd Destafino had a longstanding business relationship with 1210383

his (now former) mother-in-law, Georgia Lay, that soured after Destafino

and Lay's daughter divorced. In the aftermath of the divorce, Lay began

interfering with Destafino's property and business interests. Destafino

eventually sued, claiming that Lay had trespassed on his property,

interfered with his business operations, created a nuisance, and

improperly failed to acknowledge his ownership interest in a company

that he and Lay had jointly formed. After a bench trial, the Shelby

Circuit Court entered judgment in Destafino's favor, awarding him

$167,369.03. Lay appealed. For the reasons explained below, we affirm

the trial court's judgment.

Facts and Procedural History

During the time frame relevant to this case, Destafino and Lay were

both small-business owners. Destafino had his own construction

company, while Lay owned a medical-supply sales business. Destafino

was married to Lay's daughter, Auderia Destafino, making him Lay's

son-in-law.

In 2012, Destafino began renting space in a building located on Old

Highway 280 in Chelsea ("the property"), which he used to operate his

construction company. Not long after his lease began, Destafino allowed

2 1210383

Lay to move her business into a portion of his rented space. Destafino

also completed extensive renovations -- which took three months and cost

over $50,000 -- to improve the portion of the property that Lay used for

her business.

When Destafino's landlord discovered that Destafino was allowing

an unauthorized subtenant to use the property, he served Destafino with

a notice of eviction. But instead of moving out, Destafino and Lay decided

to purchase the property from the landlord. To facilitate their purchase,

they formed a company called BDSC, Inc. Lay signed BDSC's

incorporation papers, listed herself as BDSC's registered agent, listed

both herself and Destafino as the individuals responsible for seeking

incorporation, and listed both herself and Destafino as BDSC's directors.

A few days after its formation, BDSC purchased the property from

Destafino's landlord for $228,000 via a promissory note and a mortgage

back to the seller. Destafino and Lay each signed a personal guarantee

of the note and have each made equal, monthly payments on the note

since the purchase.

Things apparently went smoothly for Destafino and Lay up until

around 2016, when Destafino and Auderia divorced. Shortly thereafter,

3 1210383

Lay and Destafino "start[ed] having problems." Those problems reached

a boiling point in 2018, when Lay began removing equipment and other

property from Destafino's portion of the property. Then, in early 2019,

Lay installed a new lock on Destafino's office and refused to give him a

key, effectively preventing him from accessing his office.

Shortly after the lockout, Destafino brought this suit against Lay,

claiming that she had trespassed on his property, interfered with his

business operations, and created a nuisance. But Destafino's suit did

little to deter Lay's behavior. Just a few days after Destafino filed his

complaint, Lay removed him from the utility and bank accounts

associated with BDSC and the property. Destafino promptly filed a

motion for emergency relief, which the trial court granted. The trial

court's order enjoined Lay from disposing of any of Destafino's things and

from interfering with his access to the property, and it ordered her to

reinstate Destafino on the accounts associated with BDSC and the

property.

Despite the trial court's order, Lay continued interfering with

Destafino's equipment and his ability to access the property. For

example, Lay took some wooden doors belonging to Destafino and used

4 1210383

them to construct a chicken coop; took additional doors and used them as

a stand for her lawnmower; removed one of Destafino's toolboxes; used

Destafino's metal duct work as a burn barrel; obstructed the sign for

Destafino's business; prevented Destafino's vehicles from entering and

exiting the premises; and dumped so much unauthorized trash into

Destafino's dumpsters that he had to make (and pay for) separate

disposal arrangements.

Destafino eventually amended his complaint to add claims related

to ownership of the property and the management of BDSC. In

particular, the amended complaint alleged that BDSC did not have a

regular corporate structure and claimed that Lay had fraudulently

misrepresented Destafino's relationship with, and financial obligations

to, the corporation. The amended complaint requested declaratory relief,

a sale for division of the property, an award of attorney fees, and any

"other, further[,] and different relief to which [Destafino] may be

entitled."

The case went to a bench trial in the spring of 2021. In support of

the claims set out in his amended complaint, Destafino argued during the

trial that he was entitled to an equal ownership interest in BDSC and its

5 1210383

assets because he had provided half the funds that the company used to

purchase and manage the property. He pointed out that he had paid at

least half of the taxes, utility bills, and payments on the note relating to

the property. And while Destafino acknowledged that he had contributed

only $18,600 in cash toward the initial payment on the property (whereas

Lay had contributed $41,842.56), he testified that he and Lay had agreed

-- as a condition to their joint purchase of the property -- that Destafino

would be entitled to a credit for prepurchase rent payments and for the

value of the prepurchase renovations that he had performed on Lay's

portion of the property.

After the trial ended, the trial court entered a final judgment

finding in Destafino's favor on all of his claims. The trial court's

judgment further provided:

"Accordingly, it is ORDERED and ADJUDGED as follows:

"….

"3. … [Lay,] as the sole shareholder of BDSC Inc., shall immediately make reimbursement to [Destafino] for the following:

"a. Eighteen Thousand Six Hundred and no/100 dollars ($18,600.00) for the initial payment for the property, made at closing;

6 1210383

"b. Sixty Five Thousand Eight Hundred Eight and 15/100 dollars ($65,808.15) for the restoration remodel of [Lay's portion of the property];

"c. Seven Thousand Nine Hundred Sixty and 88/100 dollars ($7,960.88) for payment of ½ property taxes from 2014-2020."

"4.

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