Hendler v. Claude Nolan, Inc.

15 Fla. Supp. 103
CourtCircuit Court of the 4th Judicial Circuit of Florida, Duval County
DecidedDecember 14, 1959
DocketNo. 59-852-L
StatusPublished

This text of 15 Fla. Supp. 103 (Hendler v. Claude Nolan, Inc.) is published on Counsel Stack Legal Research, covering Circuit Court of the 4th Judicial Circuit of Florida, Duval County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hendler v. Claude Nolan, Inc., 15 Fla. Supp. 103 (Fla. Super. Ct. 1959).

Opinion

WILLIAM H. MANESS, Circuit Judge.

Order: The question before this court on defendant’s motion to dismiss plaintiff’s amended complaint, and on which briefs have been submitted, is not the sufficiency of the complaint to state a cause of action against defendant in either count one or count two, but whether or not the allegations thereof are sufficient to support a claim for punitive or exemplary damages without which this case would not meet the jurisdictional requirements of this court and should be transferred to the civil court of record of Duval County pursuant to rule 1.39 of the rules of civil procedure.

Construing the allegations of the amended complaint in a light most favorable to plaintiff so as to find therein at least a jury question (if one exists) as to her claim for punitive damages, it may be said that on July 3, 1958 in negotiating for the purchase of a 1958 Pontiac from defendant, plaintiff laid down three requirements, to-wit — it must be (1) “factory perfect in condition”, (2) “undamaged and unused” and (3) so new that it would be “figuratively ‘wrapped in cellophane with a ribbon around it’ ”. It may further be said that defendant undertook to meet these requirements and gave assurances that the car to be sold and delivered to plaintiff was in fact— (1) “a standard quality, new automobile in factory perfect condition”, (2) “undamaged and unused” and (3) “of good material and workmanship”; but that in truth and in fact, contrary to defendant’s assurances and representations, the automobile actually delivered and sold by defendant to plaintiff was “a damaged 1958 Pontiac” which was also “defective in material and workmanship”, which facts were well known to defendant and which plaintiff had no way of knowing or finding out prior to the purchase and delivery of the automobile. The original complaint was filed herein exactly one year later on July 3, 1959.

Plaintiff contends that the foregoing allegations make out a cause of action in tort for fraud and deceit, but this court is of the opinion that such allegations are essentially based on an alleged breach of contract sounding in tort. But assuming such allegations constitute an action ex delicto, it does not necessarily follow that punitive damages are recoverable.1

Construing count one of said complaint, hereinabove summarized, to be essentially a breach of contract sounding in tort, in such instances the Supreme Court of Florida has laid down the rule [105]*105with respect to punitive damages in Griffith v. Shamrock Village, Inc., 94 So. 2d 854, at page 858, in the following language —

“The general rule is that punitive damages are not recoverable for breach of contract, irrespective of the motive of defendant. But where the acts constituting a breach of contract also amount to a cause of action in tort there may be a recovery of exemplary damages upon proper allegations and proof. In order to permit a recovery, however, the breach must be attended by some intentional wrong, insult, abuse or gross negligence which amounts to an independent tort. 25 C.J.S. Damages, § 120, pp. 716-717.”

The Supreme Court has further held that allowance of punitive damages in tort actions is dependent upon a showing of malice, moral turpitude, wantonness or outrageousness of the alleged tort. See Dr. P. Phillips & Sons, Inc. v. Kilgore, 1943, 152 Fla. 578, 12 So. 2d 465; Ross v. Gore (Fla. 1950), 48 So. 2d 412. See also Corbin on Contracts (Copyright, 1951), Volume 5, Section 1077, at pages 366 and 367. There, it is stated that —

“ * * * It can be laid down as a general rule that punitive damages are not recoverable for breach of contract, although in certain classes of cases, there has been a tendency to instruct the jury that they may award damages in excess of compensation and by way of punishment. These cases, however, are cases that contain elements that enable the court to regard them as falling within the field of tort or as closely analogous thereto.”

Such a case is Kress v. Soules, 255 S.W. 2d 244 (Tex. Civ. App. 1953), where Soules executed a contract to purchase real estate from Kress, after which Kress refused to consummate the sale according to the contract and advised Soules that he had sold the property to another man for more money and requested a release from the contract; thereafter, after Soules filed suit for specific performance and filed a notice of lis pendens, Kress conveyed the subject property to a third person prior to which Kress notified Soules that unless he was released from his contract, that he, Kress, would cloud the title and involve Soules in lengthy litigation, all of which the complaint alleged was in wanton disregard of Soules’ rights under the contract and was malicious and willful.

Another example of such conduct as would constitute an independent tort is the case of Etter v. Von Sternberg, 244 S.W. 2d 321 (Tex. Civ. App. 1951), where a deputy court reporter sued the official court reporter on a contract for sums claimed to be due him for [106]*106work in connection with preparation and reporting of cases in the federal district court. The facts alleged in that case to support a charge of punitive damages were, and the jury so found, that under the contract which the plaintiff-reporter had with the defendant, plaintiff was to receive 60% of monies received by defendant for plaintiff’s work, less typing costs, and that defendant had breached this contract by misrepresenting the actual amounts derived from work and concealing the number of copies sold.

In applying the foregoing principles to the facts alleged in plaintiff’s complaint herein, it appears that the allegations of the representations with respect to “factory perfect in condition”, “unused”, and so new that it would be “figuratively ‘wrapped in cellophane with a ribbon around it’ ”, as well as the alleged representations that the automobile was “a standard quality, new automobile in factory perfect condition”, and “of good material and workmanship”, must be regarded as no more than “puffing” or “trade-talk”, insofar as such language is relied upon to support a claim for punitive damages. It is obvious to a layman that such standards cannot be achieved or expected of any mechanical device as complicated as an automobile as it is that a puncture-proóf tire can go flat. The failure to deliver such an automobile after making such a written or implied guaranty cannot form a basis for the award of punitive damages any more than the representations that a - stepladder will never break can support a cause of action for damages. See Lambert v. Sistrunk (Fla.), 58 So. 2d 434. This is not to say that such representations will not support an action for compensatory damages for breach of an express ór implied warranty.

Having thus disposed of all the alleged misrepresentations, except that the automobile would be “undamaged” when, in fact, it was “a damaged 1958 Pontiac model”, the sole question now remains as to whether or not that representation, standing alone, is sufficient to support an award of punitive damages.

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Related

Ross v. Gore
48 So. 2d 412 (Supreme Court of Florida, 1950)
Kress v. Soules
255 S.W.2d 244 (Court of Appeals of Texas, 1953)
Etter v. Von Sternberg
244 S.W.2d 321 (Court of Appeals of Texas, 1951)
Lambert v. Sistrunk
58 So. 2d 434 (Supreme Court of Florida, 1952)
Griffith v. Shamrock Village
94 So. 2d 854 (Supreme Court of Florida, 1957)
Carraway v. Revell
116 So. 2d 16 (Supreme Court of Florida, 1959)
Dr. P. Phillips & Sons, Inc. v. Kilgore
12 So. 2d 465 (Supreme Court of Florida, 1943)
Florida Southern Railway Co. v. Hirst
30 Fla. 1 (Supreme Court of Florida, 1892)

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Bluebook (online)
15 Fla. Supp. 103, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hendler-v-claude-nolan-inc-flacirct4duv-1959.