Larry Schwartz v. Nicholas Menas, Esq. (085184) (Monmouth County and Statewide)

CourtSupreme Court of New Jersey
DecidedAugust 17, 2022
DocketA-54/55-20
StatusPublished

This text of Larry Schwartz v. Nicholas Menas, Esq. (085184) (Monmouth County and Statewide) (Larry Schwartz v. Nicholas Menas, Esq. (085184) (Monmouth County and Statewide)) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Larry Schwartz v. Nicholas Menas, Esq. (085184) (Monmouth County and Statewide), (N.J. 2022).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

Larry Schwartz v. Nicholas Menas, Esq. (A-54/55-20) (085184)

Argued April 26, 2022 -- Decided August 17, 2022

PATTERSON, J., writing for a unanimous Court.

In these consolidated appeals, which arise from two actions based on real estate development disputes, the Court considers whether plaintiffs Larry Schwartz and NJ 322, LLC should be barred from presenting evidence of lost profits damages under Weiss v. Revenue Building & Loan Association, 116 N.J.L. 208 (E. & A. 1936), and the “new business rule,” which bars claims for lost profits by new businesses on the ground that no such claim can be proven with reasonable certainty.

In the first action, plaintiffs sued their former legal counsel, two real estate developers, and executives employed by the developers, alleging that defendants’ tortious conduct deprived them of the opportunity to construct an affordable housing complex on a property in Monroe Township. Schwartz had formed NJ 322, LLC with a developer to build a market-rate rental and commercial development on the property. Plaintiffs contend that defendants arranged to have the property rezoned so that only affordable housing could be built on it, at which time the developer withdrew and Schwartz had no alternative but to sell the property.

Schwartz conceded that he had no experience with or knowledge of the requirements imposed on developers of affordable housing, but asserts that he intended to act as the property’s developer. Plaintiffs’ damages expert prepared a report that included his opinion on “the profits that would likely have been earned by [p]laintiffs in the event that their development goals and objectives in connection with the development of the Project had not been frustrated” by defendants’ alleged conduct. The expert presented two lost profits damages models for the Monroe Township development: the profit plaintiffs would have achieved if the development had proceeded as originally planned, and the profit had plaintiffs been the ones to construct the affordable housing project that was actually built. The expert’s report did not acknowledge that Schwartz had never been involved with a residential development or built housing of any kind. Based on the new business rule, the trial court granted defendants’ motion to bar testimony by plaintiffs’ expert.

1 In the second action, Schwartz sued his former counsel for legal malpractice and breach of contract arising from the proposed development of two properties in Egg Harbor Township. Schwartz served an expert report presenting three lost profits damages models that varied according to whether and how much of the property would be age-restricted. The report did not acknowledge that Schwartz had never developed residential housing, but rather assumed that Schwartz would have obtained financing and would have partnered with experienced developers to construct the housing. The trial court found that Schwartz’s Egg Harbor venture was a new business and barred the expert opinion pursuant to the new business rule.

The Appellate Division affirmed in both cases. The court considered itself constrained to follow Weiss and apply the new business rule; it also held that, even if the new business rule did not apply, the expert’s opinions were too speculative to meet the standard of reasonable certainty required for lost profits damages. The Court granted certification. 246 N.J. 139 (2021); 246 N.J. 145 (2021).

HELD: The Court joins the majority of jurisdictions that reject a per se ban on claims by new businesses for lost profits damages, and it declines to follow Weiss to the extent that it bars any claim by a new business for such damages. Claims for lost profits damages are governed by the standard of reasonable certainty and require a fact-sensitive analysis. Because it is substantially more difficult for a new business to establish lost profits damages with reasonable certainty, a trial court should carefully scrutinize a new business’s claim that a defendant’s tortious conduct or breach of contract prevented it from profiting from an enterprise in which it has no experience and should bar that claim unless it can be proven with reasonable certainty. The Court remands these matters so that the trial court may decide defendants’ motions in accordance with the proper standard.

1. Weiss involved a lease dispute in which the plaintiff alleged the defendant’s breach deprived him of the opportunity to operate two rooming houses. 116 N.J.L. at 209. At trial, the plaintiff was permitted to estimate the profit that he would have earned from the defendant’s buildings based on the profit he had earned by operating rooming houses at other locations. Id. at 213-23. Observing that damages for breach of contract “must be the reasonably certain and definite consequences of the breach,” the Court of Errors and Appeals noted that, in new businesses, “the prospective profits are too remote, contingent and speculative to meet the le gal standard of reasonable certainty.” Id. at 210, 212. The Weiss court found it was error in that case to consider the proposed rooming house’s anticipated profits, which were “remote, speculative and problematical.” Id. at 213. The Court has not previously considered whether a plaintiff’s status as a new business constitutes an important factor in determining whether lost profits damages may be proven with reasonable certainty, or whether it bars such damages entirely. Prior case law has thus left unresolved the question raised by this appeal. (pp. 17-21) 2 2. In the decades since the Court of Errors & Appeals decided Weiss, a majority of courts in other jurisdictions have recognized that, although it is difficult for a new business to meet the standard of reasonable certainty, a per se ban on any claims for lost profits damages by a new business is unwarranted. Nonetheless, abrogation of the new business rule does not produce a free-for-all. Under New York law, the new business rule is not a per se rule forbidding the award of lost profits damages to new businesses, but rather an evidentiary rule that creates a higher level of proof needed to achieve reasonable certainty as to the amount of damages. Illinois law similarly imposes a high standard on new business claims for lost profits damages but does not bar such claims entirely. Recognition that it is difficult for a new business to prove lost profits claims is consistent with the approach of the Restatement (Second) of Contracts, which recognizes that it is “more difficult” but still possible to prove loss of profits for new businesses “with the aid of expert testimony, economic and financial data, market surveys and analyses, business records of similar enterprises, and the like.” See § 352 & cmt. b. Most courts that have considered the new business rule reject a per se bar for lost profits claims by new businesses and instead carefully scrutinize such claims, treating a new business’s inexperience as an important factor in the reasonable certainty standard. (pp. 22-25)

3. Reiterating the general rule under New Jersey law that lost profits may be recoverable if they can be established with a reasonable degree of certainty, bu t anticipated profits that are remote, uncertain or speculative are not recoverable, the Court concurs with the majority of courts that reject a per se rule barring any new business’s claim for lost profits damages. To the extent that Weiss can be read to adopt such a per se bar, the Court departs from the test prescribed in that case. The Court does not view a new business to be in the same position as an established business with respect to damages claims, however.

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Larry Schwartz v. Nicholas Menas, Esq. (085184) (Monmouth County and Statewide), Counsel Stack Legal Research, https://law.counselstack.com/opinion/larry-schwartz-v-nicholas-menas-esq-085184-monmouth-county-and-nj-2022.