Jonathan Lancaster and Cassie Bickham v. Andrea Miller and Jan Macko

CourtCourt of Appeals of Mississippi
DecidedFebruary 23, 2021
Docket2019-CA-01715-COA
StatusPublished

This text of Jonathan Lancaster and Cassie Bickham v. Andrea Miller and Jan Macko (Jonathan Lancaster and Cassie Bickham v. Andrea Miller and Jan Macko) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jonathan Lancaster and Cassie Bickham v. Andrea Miller and Jan Macko, (Mich. Ct. App. 2021).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2019-CA-01715-COA

JONATHAN LANCASTER AND CASSIE APPELLANTS BICKHAM

v.

ANDREA MILLER AND JAN MACKO APPELLEES

DATE OF JUDGMENT: 10/17/2019 TRIAL JUDGE: HON. CLAIBORNE McDONALD COURT FROM WHICH APPEALED: LAMAR COUNTY CIRCUIT COURT ATTORNEY FOR APPELLANTS: DANIEL MYERS WAIDE ATTORNEYS FOR APPELLEES: PATRICK H. ZACHARY VICKI R. LEGGETT NATURE OF THE CASE: CIVIL - TORTS-OTHER THAN PERSONAL INJURY AND PROPERTY DAMAGE DISPOSITION: REVERSED AND REMANDED - 02/23/2021 MOTION FOR REHEARING FILED: MANDATE ISSUED:

BEFORE BARNES, C.J., McDONALD AND LAWRENCE, JJ.

McDONALD, J., FOR THE COURT:

¶1. Jan Macko and Andrea Miller sold Jonathan Lancaster and Cassie Bickham a house

that was titled in the name of Macko’s limited liability company, Magnolia Properties and

Remodel LLC (Magnolia LLC). After moving into the house, Lancaster and Bickham

discovered problems with the plumbing, electrical, and roofing conditions. Lancaster and

Bickham filed suit for fraud and breach of contract against Magnolia LLC, ICOM LLC, and

Miller and Macko individually in the Lamar County Circuit Court. Miller and Macko filed

for summary judgment, claiming that they were protected from individual liability by virtue

of their membership in the limited liability company. The circuit court granted them summary judgment, holding that Lancaster and Bickham failed to present proof of the

elements needed to pierce the corporate veil and because there was no genuine issue of

material fact regarding Miller’s and Macko’s individual liability.

¶2. Although the parties briefed several issues, after oral argument, there remains only

one issue on appeal: whether Miller’s and Macko’s personal involvement made them each

individually liable for the damages. Therefore, the matter amounts to only a

misrepresentation case. Finding that the circuit court erred in holding that there was no

genuine issue of material fact regarding Miller’s and Macko’s individual liability, we reverse

the court’s ruling and remand the case for further proceedings.

Statement of the Facts and Procedural History

¶3. Macko formed Magnolia LLC on April 26, 2016, and served as the manager and a

member of the company. Her daughter, Miller, was a member of the LLC. The LLC had an

operating agreement and its own bank account. On May 25, 2016, Macko and Miller

purchased a house located at 206 Lamar Avenue, Hattiesburg, Mississippi, from James

Michael Pickett and Kathy Diane Pickett. The title to the home was in the name of the LLC.

When selling the house, James advised Miller and Macko that they should replace the roof.

According to Pickett, although the roof had been replaced only ten years prior to Magnolia

LLC’s purchase, it had started leaking again. James also advised Miller and Macko that they

should replace the plumbing in the kitchen and utility room because of water leaks.

¶4. Miller and Macko remodeled the Lamar Avenue house between May 2016 through

2 October 2016, but they replaced only certain parts of the roof, some plumbing items, and

some electrical sockets. To finance the renovations, Macko obtained two loans in the name

of the LLC for $114,561 and $12,000. Macko and Miller contributed $15,924 of their

personal money to purchase and renovate the house.

¶5. On October 12, 2016, Miller used her personal Facebook account to advertise the

Lamar Avenue house for the sale price of $149,900. In the Facebook post, Miller said the

house was a “totally renovated home for sale by owner.” Miller also posted that she was

“[n]ot sure of exact year built. It has all new wiring, roof, etc.”

¶6. Lancaster and Bickham were looking to purchase a house when they came across

Miller’s Facebook post. They contacted Miller to view the house. Following the tour, in

November 2016, Lancaster and Bickham made an offer to buy the house based upon the

representations made personally by Miller and Macko. During the negotiations to purchase

the property, Lancaster and Bickham claimed that Miller and Macko represented that the

entire house had been renovated and that renovations to the house were covered by

warranties. The alleged renovations included new plumbing, a new electrical system, and

a new roof.

¶7. On November 4, 2016, Bickham and Lancaster signed a purchase contract,1 which

only had Miller and Macko listed as the sellers. On that same date, Bickham and Lancaster

also signed a “Property Condition Disclosure Statement” that Miller and Macko also signed

1 Lancaster and Bickham purchased the house for $148,000.

3 as the sellers. “Magnolia Properties” was listed at the beginning of the disclosure. The

disclosure statement stated that the house had been totally renovated. In exchange, Lancaster

gave Macko and Miller a check for $500 as earnest money on the purchase that same day.

The check was made payable to “Magnolia Properties.”

¶8. Lancaster and Bickham hired ICOM LLC to prepare an independent (although

limited) inspection2 of the house on December 1, 2016. ICOM indicated that for the items

it inspected, the house was in good condition. On February 2, 2017, Lancaster and Bickham

signed closing documents, which listed Magnolia LLC as the owner. That same day, the

home was conveyed to Lancaster and Bickham from Magnolia LLC by a deed signed by

“Macko/Manager/Member” and “Miller/Member.”

¶9. Shortly after purchasing the house, Lancaster and Bickham discovered severe and

hazardous issues with the home, including but not limited to electrical shortages, burst water

pipes, and a leaking roof. They also claimed that they discovered that none of the

renovations were covered by warranties as promised by Miller and Macko. According to

Lancaster and Bickham, they contacted the contractors who had previously worked on the

house. These contractors said that Macko and Miller fired them before they finished their

work3 because they recommended that the house needed additional work, including replacing

the entire roof and replacing the entire electrical system. Because the contractors were fired

2 Pursuant to the Mississippi Home Inspector Division Standards of Practice and Code of Ethics, Rule 13.2, an inspector is not required to inspect certain places of the house. 3 The record does not specify when the contractors were fired.

4 and the work was not completed, none of the renovations were covered by warranty.

Lancaster and Bickham presented estimates in excess of $134,745 for repairs needed to

house.

¶10. On January 30, 2018, Lancaster and Bickham filed suit against Magnolia LLC, ICOM

LLC,4 and against Miller and Macko individually in the Lamar County Circuit Court.

Specifically, Lancaster’s and Bickham’s claims against Miller and Macko individually

included the failure to disclose known issues with the house, breach of contract, negligent

misrepresentation, intentional and/or fraudulent misrepresentation, negligent infliction of

emotional distress, and breach of the duty of good faith. Lancaster and Bickham argued that

they were not aware that an LLC owned the house until they closed on the property.

Lancaster and Bickham requested a jury trial and judgment against all the listed defendants

for actual, compensatory, pecuniary, special, and punitive damages, specific performance,

and rescission of the contract.

¶11. Magnolia LLC answered the complaint admitting that some representations of the

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