I-20 Self Storage, LLC v. Big Stuff Storage, L.L.C.

CourtLouisiana Court of Appeal
DecidedJanuary 11, 2023
Docket54,814-CA
StatusPublished

This text of I-20 Self Storage, LLC v. Big Stuff Storage, L.L.C. (I-20 Self Storage, LLC v. Big Stuff Storage, L.L.C.) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
I-20 Self Storage, LLC v. Big Stuff Storage, L.L.C., (La. Ct. App. 2023).

Opinion

Judgment rendered January 11, 2023. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 54,814-CA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

I-20 SELF STORAGE, LLC Plaintiff-Appellant

versus

BIG STUFF STORAGE, L.L.C. Defendant-Appellee

Appealed from the Fourth Judicial District Court for the Parish of Ouachita, Louisiana Trial Court No. 19-2252

Honorable Daniel Ellender, Judge

HUDSON, POTTS & BERNSTEIN, LLP Counsel for Appellant By: G. Adam Cossey Jason R. Smith

NELSON, ZENTNER, SARTOR Counsel for Appellees, & SNELLINGS Big Stuff Storage, LLC, By: George M. Snellings, IV & Jere C. Spence Allison M. Jarrell

Before PITMAN, STEPHENS, and MARCOTTE, JJ. PITMAN, J.

Plaintiff I-20 Self Storage, LLC, appeals the judgment of the trial

court dismissing its suit to rescind a sale of a self-storage property on the

basis of fraud or error against Defendants, Big Stuff Storage, L.L.C., and its

member, Jere Spence. For the following reasons, we affirm.

FACTS

The following facts are gleaned from the record and the transcript of

the trial held on November 29 and 30, 2021.

Plaintiff wanted an investment and observed Defendants’ storage

business, which was advertised for sale by DB Real Estate agent Deanna

Norman. Spence had previously been a real estate agent with her agency.

Plaintiff, through its Member/Manager Marlin S. Jones, made an

appointment to tour the property.

Spence was present at the initial visit and provided Jones with an

occupancy analysis report, a master list of all tenants and an email that he

wrote stating that the miscellaneous expenses of the building included the

cost of energy, a dumpster, property taxes, insurance and flood insurance.

He informed Jones that there were 266 units total, of which 132 were vacant

at that time, and that the actual rent generated per month, if all units were

occupied, was $12,205.

Jones asked for records to verify the income, but the records and

accounts for the property were combined with that of another storage

business Spence owned and were not available. Spence stated that there

were no traditional “books” for the business and that all documents were

created from information contained in QuickStor, a software program for

self-storage businesses. Spence and Jones began negotiating a price for the property. Spence

hoped to sell it for over $1 million. Norman requested the “rent rolls” from

Spence to document the property’s occupancy and monthly income, which

she would then convey to Jones. Spence provided her with the information

in April, July and October 2018, which was based on data he recorded in

QuickStor. Spence informed Jones that the information he provided might

not be accurate because he had allowed discounts on some of the units. He

did not think the discounts were significant enough to disclose unless and

until Plaintiff became a serious buyer.1 Spence stated that the income

generated was approximately $11,000 to $12,000 for the time period of

October through December 2018.

In November 2018, Spence provided Jones with an updated

occupancy analysis report that showed an increase in tenants after the rent

roll provided five days earlier. This report increased the amount of

incoming rent to $12,705 per month. After appraisals were conducted,

Spence lowered his price to $910,000, and Plaintiff agreed to that contract.

Prior to closing, Jones learned that flood insurance would be more

than $5,000 rather than the $1,800 that Spence had reported paying. This

amount was greater because the insurance provided to Spence covered only

the office of the property and none of the storage units. The bank financing

the purchase required flood insurance on the entire property. Jones was

going to renege on the sale, but Spence offered to lower the price to

$870,000. Jones agreed to the purchase price reduction, and the sale of the

1 Norman testified that she never had any reason to question the information Spence provided regarding whether the rent prices listed were accurate, whether the list included tenants from the other location or that it included tenants who were not actually paying their rent. She stated that had she known of inaccuracies, she would have had to disclose that information to Plaintiff. 2 property took place on January 7, 2019. The document by which Plaintiff

obtained title is entitled “Sale of Property,” and Defendants conveyed “the

following described property” found in Exhibit A attached to the document.

Exhibit A is a list of 12 lots, with their legal descriptions, situated at 711 N.

11th Street, West Monroe, Louisiana.

The act of sale of property also states that the sale is “As is, Where is”

and contains the following disclaimer language:

Vendor hereby disclaims any warranty, guaranty or representation, oral or written, past, present or future, of, as to, or concerning, (i) the nature and condition of the Property, including the suitability thereof for any and all activities and uses which Vendee may elect to conduct thereon; (ii) the existence of any environmental hazards or conditions thereon (including the presence of asbestos) or compliance with all applicable laws, rules or regulations; and (iii) the compliance of the Property or its operations with any laws, ordinances or regulations of any governmental or other body. The sale of the Property Is made on an “AS IS,” “WHERE IS” basis, and Vendee expressly acknowledges that, except as to title to the Property, Vendor makes no warranty or representation express or implied, or arising by operation of law, including but not limited to any warranty of condition, habitability, merchantability or fitness for a particular purpose, in respect of the Property. Vendee agrees that Vendor, except as to warranty of title, shall not be responsible or liable to Vendee for any construction defect, errors, omissions or on account of any other conditions affecting the Property, as Vendee is purchasing the Property AS IS, WHERE IS and WITH ALL DEFECTS AND VICES, WHETHER LATENT OR APPARENT, KNOWN OR UNKNOWN. Except as to the warranty of title, Vendee hereby fully releases Vendor, its employees, officers, directors, partners, representatives and agents from any and all claims that it may now have or hereafter acquire against Vendor, its employees, officers, directors, partners, representatives and agents for any cost, loss, liability, damage, expense, demand, action or cause of action arising from or related to any construction defects, errors, omissions, or other conditions affecting the Property. Vendee further acknowledges and agrees that this release shall be given full force and effect, according to each of its expressed terms and provisions, including, but not limited to, those relating to unknown and unsuspected claims, damages and causes of action. Vendee expressly waives the warranty of 3 fitness and warranty against redhibitory vices imposed by La. Civ. Code Ann. arts 2475, 2524 or any other applicable state or federal law. Vendee further waives any rights it may have in redhibition or to a reduction in or restitution of purchase price and revenues and/or costs pursuant to La. Civ. Code Ann. arts 2520 to 2548 inclusive, in connection with the purchase of the Property. Vendee expressly acknowledges such waivers and Vendee's express exercise of its rights to waive warranty pursuant to Louisiana Civil Code Article 2548.

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I-20 Self Storage, LLC v. Big Stuff Storage, L.L.C., Counsel Stack Legal Research, https://law.counselstack.com/opinion/i-20-self-storage-llc-v-big-stuff-storage-llc-lactapp-2023.