Maletz v. Sandler

4 Mass. L. Rptr. 697
CourtMassachusetts Superior Court
DecidedDecember 15, 1995
DocketNo. 953721
StatusPublished

This text of 4 Mass. L. Rptr. 697 (Maletz v. Sandler) is published on Counsel Stack Legal Research, covering Massachusetts Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Maletz v. Sandler, 4 Mass. L. Rptr. 697 (Mass. Ct. App. 1995).

Opinion

Welch, J.

The plaintiff, Marlene Maletz, brought several different causes of action against named defendants. This decision addresses only one count of common law fraud (Count I) against defendant Paul Sandler. Maletz sues Sandler “in his individual capacity and as executor of the estate of the late Dorothy Sandler.” The plaintiff alleges that Sandler intentionally and materially misrepresented that there was no leaking in the basement of a house which Maletz was considering buying. These material misrepresentations allegedly were made with an intent to induce her to purchase the property. Maletz relied upon Sandler’s misrepresentations, purchased the property, and has suffered damages.

This motion to dismiss was brought by defendant, Paul Sandler, pursuant to Mass.R.Civ.P. 12(b)(6). Sandler’s motion to dismiss is based on two main theories: 1) an “as is” disclaimer in the purchase and sale agreement and 2) the statute of limitations. After holding a hearing on defendant’s motion to dismiss, the court concludes that this motion must be ALLOWED.

The applicable factual allegations are taken from the complaint. Plain tiff Maletz, a Massachusetts attorney, after some negotiation and other preliminaries contacted to purchase a home at 481 Dudley Road, Newton, Massachusetts from Paul Sandler. Defendant Paul Sandler, who was acting as “executor of the estate of Dorothy Sandler,” his mother, listed the property for sale. Complaint ¶7. The neighborhood has a very high water table, and most of the homes in the immediate area had drainage problems and basement flooding. Both of these conditions were known to Sandler (¶10 of the complaint). Also, Sandler had the basement walls painted gray to cover any water stains from prospective buyers (¶12). On August 8th, Sandler signed and dated a “Statement of Conditions” regarding the property to be sold. This statement (which was delivered to plaintiff in mid to late August) included representations that there was no leaking, water seepage, or dampness in the basement. Complaint ¶20.

[698]*698Maletz viewed the property and signed a written offer to purchase the property on August 10, 1992. Complaint ¶13. She viewed the property (including the basement) again five days later. In late August and September, plaintiff had the house and foundation inspected several times. Complaint ¶¶14-19. On August 27, 1992 the purchase and sale agreement was signed by plaintiff and defendant Sandler. November 2, 1992 was the closing date.

The property was inspected by a home inspector at least once, and a structural engineer several times. The engineer found some structural problems. An agreement was worked out between Maletz and Sandler, whereby Sandler would deduct $5,000.00 from the purchase price of the property at closing.

Maletz moved into the property on Saturday, November 21, 1992. That evening and over the next two days, it rained causing flooding in the basement. The basement and backyard were flooded on several occasions in November, December and January of 1992-1993. Maletz excavated around the foundation in order to waterproof the basement. Additional renovations were also needed which resulted in a $40,000.00 expenditure.

DISCUSSION

A. The Purchase and Sales Disclaimer

Sandler first argues that a negotiated, non-boiler plate provision in the purchase and sale agreement that sold the property “as is” made any earlier alleged misrepresentations irrelevant. The Massachusetts courts have looked at certain factors (1) counsel representation, (2) negotiation at arm’s length, and (3) a boiler-place provision versus a contract which is a complete, accurate and final understanding of the parties, in determining whether there is any possible survival of warranties or representations. Even when an express provision in a Purchase and Sale Agreement provides that any prior warranties or representations do not apply, and the buyer takes the property “as is” the court may still look to see if the “as is” provision was negotiated at arm’s length.

Sandler relies on Greenery Rehabilitation Group, Inc. v. Antaramian, 36 Mass.App.Ct. 73 (1994). In Greenery, the buyer (Greenery) bought a building from defendants. The seller represented to Greenery that the tenants were “as good as gold,” “solid,” “in good standing,” “rents right up to date.” Four months after Greenery closed on the building, Northern Construction, the building’s “long term tenant,” defaulted on their lease and vacated the building.

There was a clause in Greenery’s purchase and sale agreement similar to the clause in this case. Greenery’s purchase and sale clause allowed all prior warranties and representations to be merged into the purchase and sale agreement and neither party could rely on past representations. The court found that the statements made by the seller, regardless of how they were viewed, were “eliminated by the purchase agreement itself ... It is clear beyond doubt that the question of the possible survival, beyond the date of formal agreement, of any antecedent representations or warranties was itself negotiated seriously and at length.” Greenery, 36 Mass.App.Ct. at 76-77 (1994). The court concluded that the parties negotiated and agreed to these provisions and the provision’s were not “boilerplate.” See McEvoy Travel Bureau, Inc. v. Norton Co.,2 408 Mass. 704 (1990); Turner v. Johnson & Johnson,3 809 F.2d 90 (1st Cir. 1986).

In contrast, Maletz relies on Sheehy v. Lipton Industries, Inc., 24 Mass.App.Ct. 188 (1987). In Sheehy, the buyer inquired whether the property had any potential hazardous material. The broker responded, “Don’t worry about it.” The sale was finalized which included an “as is” clause in the purchase and sale agreement. The buyer later discovered that parts of the property contained hazardous material. The Sheehy court followed the line of Massachusetts cases which “rejects the assertion of‘as is’ and like clauses as an automatic defense to allegations of fraud and deceit.” Sheehy, 24 Mass.App.Ct. at 193. See Bates v. Southgate, 308 Mass. 170 (1941).

There is undoubtedly some tension between Greenery and Sheehy as they apply to this case. Under Greenery, the rationale would be that Maletz is an attorney and is represented by counsel. She had an inspector and a structural engineer look over the property and basement several times. She negotiated a $5,000.00 settlement for defects in the foundation. All this negotiation was done at arm’s length. However, under Sheehy, the Massachusetts Appeals Court rejected an “as is” clause as a defense to fraud. Here, Maletz is alleging fraud.

Regardless of who has the better argument, these issues require resolving facts well beyond the allegations contained in the pleadings. More discovery is needed to determine how much deliberation and negotiation there was between the parties in drafting the purchase and sale agreement. For example, was the provision in the rider of the P & S Agreement regarding taking the property “as is” merely boilerplate, or was it a final, complete and accurate understanding of the parties which merged all prior representations? These are matters better addressed on a summary judgment motion after more discovery.

B.

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Related

Greenery Rehabilitation Group, Inc. v. Antaramian
628 N.E.2d 1291 (Massachusetts Appeals Court, 1994)
Sheehy v. Lipton Industries, Inc.
507 N.E.2d 781 (Massachusetts Appeals Court, 1987)
McEvoy Travel Bureau, Inc. v. Norton Co.
563 N.E.2d 188 (Massachusetts Supreme Judicial Court, 1990)
Bates v. Southgate
31 N.E.2d 551 (Massachusetts Supreme Judicial Court, 1941)

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Bluebook (online)
4 Mass. L. Rptr. 697, Counsel Stack Legal Research, https://law.counselstack.com/opinion/maletz-v-sandler-masssuperct-1995.