McNamara v. Corte-Real

2009 Mass. App. Div. 215, 2009 Mass. App. Div. LEXIS 63
CourtMassachusetts District Court, Appellate Division
DecidedOctober 13, 2009
StatusPublished
Cited by3 cases

This text of 2009 Mass. App. Div. 215 (McNamara v. Corte-Real) is published on Counsel Stack Legal Research, covering Massachusetts District Court, Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McNamara v. Corte-Real, 2009 Mass. App. Div. 215, 2009 Mass. App. Div. LEXIS 63 (Mass. Ct. App. 2009).

Opinion

Williams, RJ.

After the plaintiff, Seth T. McNamara (“McNamara”), had purchased a used pickup truck from the defendant, Michael J. Corte-Real (“Corte-Real”), he sought to rescind the sale transaction. Following a jury-waived trial, the judge found in favor of Corte-Real on the basis of McNamara’s failure to prove both that there had existed undisclosed defects in the truck that would have entitled him to rescind the sale, and that he had returned, or would be returning, the truck to Corte-Real. McNamara appealed, claiming it was error for the trial court not to have found that he was entitled to rescind the sale. Additionally, McNamara argued that the sale was invalid in any event because Corte-Real had not transferred title of the truck to him. We find no error, and dismiss the appeal.

Corte-Real bought a 1999 Ford F-250 pickup truck from one Maynard in March, 2005. Maynard transferred title to Corte-Real, but Corte-Real did not register the truck. In December, 2005, Corte-Real sold the truck to his close friend, McNamara. Although it was undisputed that both parties knew the truck needed certain repairs, there was disagreement at trial as to whether McNamara knew of the truck’s faulty brakes.

On December 6, 2005, the two signed an agreement for the purchase and sale of the truck at a price of $12,000.00. The two had agreed, however, that McNamara would pay only $10,000.00 for the truck McNamara borrowed $11,400.00 from a credit union and paid that sum to Corte-Real, who returned $1,400.00 to McNamara. The evidence permitted a finding that the latter sum was to be used either to register and insure the truck, or to effect certain repairs to the truck, including to its brakes.

When McNamara tried to register the truck, the registry of motor vehicles would not allow him to do so, reportedly because the title he had obtained from Corte-Real showed only the Maynard transaction and did not name Corte-Real as an owner. After Corte-Real had not, as he had promised, rectified that problem, McNamara went back to Maynard and obtained a new title, with which McNamara was satisfied, even though he did not try again to register the vehicle.

A few days after the purchase, McNamara had the truck towed to a repair facility (“Jim’s”). Whether McNamara told Jim’s principal, James Medeiros (“Medeiros”), that he knew of the brake problems and asked Medeiros to check the brakes is disputed. [216]*216Medeiros, in any event, told McNamara that the brakes were severely defective, and provided a repair estimate in excess of $3,000.00 for work required to render the truck operable and safe. McNamara and Corte-Real talked about splitting the repair costs, but reached no resolution. McNamara, purportedly, served a written notice of rescission pursuant to G.L.c. 90, §7Nl/4(8) on Corte-Real on January 5, 2006, seeking the return of his purchase money.2 Receiving no such relief, he commenced this action.

The trial judge noted the parties’ friendship and found that McNamara had been familiar with the truck before he bought it, and that the sale was valid. He also found that Corte-Real had agreed to pay the cost of repairing the water pump and serpentine belt assembly, but once Jim’s determined that more work, at a cost in excess of $3,000.00, was needed, McNamara declined to proceed with the work, and did not retrieve the truck from Jim’s. The truck had been towed from Jim’s to Boss Towing, Inc. (“Boss Towing”), where it remained as of the time of the judgment. The trial judge correctly ruled that McNamara bore the burden of establishing the elements of rescission, Raymond Syndicate, Inc. v. American Radio & Research Corp., 263 Mass. 147, 155-156 (1928), by advancing proof of the existence of undisclosed defects in the truck at the time of sale, and of his return, or tender of return, of the truck to Corte-Real. The latter derives from the essence of the doctrine of rescission, which is to place the parties in the position they were in before their failed transaction. Bellefeuille v. Medeiros, 335 Mass. 262, 266 (1957). McNamara, the trial judge found, had proved neither requirement by a preponderance of the evidence, and so ordered judgment for Corte-Real.3

1. McNamara’s first argument — that the trial judge erred in failing to find that McNamara was entitled to statutory rescission — is predicated on his singular view [217]*217that the evidence conclusively established that Corte-Real never informed McNamara of the truck’s brake failure. Thus, if the record before us discloses evidence that could support a conclusion that Corte-Real had revealed the defective brakes to McNamara at the time of sale, the potential rescission remedy of G.L.c. 90, §7Nl/4(8) on which McNamara relies would be unavailable to him because there would be no “undisclosed defects” to trigger the operation of the statute.

Clearly, the parties’ level of knowledge about the defective brakes was a question of fact for the trial court. See, e.g., Commonwealth v. Casale, 381 Mass. 167, 173 (1980). Although the trial judge did not issue a lengthy, detailed recitation of all facts indicative of McNamara’s knowledge about the defective brakes, he expressly found that McNamara had failed to prove that the brake problem had not been disclosed to him. “[W]e do not review questions of fact found by the judge, where such findings are supported on any reasonable view of the evidence, including all rational inferences of which it was susceptible. So long as the judge’s account is plausible in light of the entire record, an appellate court should decline to reverse it.” Lily Transp. Corp., supra at 181, quoting Demoulas, supra at 510.

The judge’s view of the nature of the parties’ transaction is supported by the record. Contrary to McNamara’s argument that the brake failure had not been disclosed to him, the record reflects sufficient evidence that would have permitted the trial judge to conclude that McNamara essentially knew as much about the defective brakes as Corte-Real did. Specifically, there was evidence that Corte-Real had told McNamara, with whom he had been friends for some 22 years and with whom he “hung out every day,” about the “brakes problem.” Corte-Real testified, specifically, that he had sold the truck to McNamara with the understanding that it had problems with the water pump, serpentine belt, and brakes. Indeed, the presumed cost of repairing those defects was the reason Cone-Real returned $1,400.00 to McNamara of the $11,400.00 McNamara had borrowed to purchase the truck.4 Because the record supports the trial judge’s view of the evidence that McNamara knew of the brake problem at the time of sale, his conclusion that McNamara had not proved entitlement to rescission on the basis of undisclosed defects was sound.

2. There was also no error in the trial judge’s determination that McNamara’s failure to return, or tender a return, of the truck to Cone-Real precluded a finding in his favor in this action.

Rescission is an equitable remedy, and, whenever possible, the result should be to return the parties to the status quo ante. Accordingly, a party seeking rescission of a contract must generally “restore or offer to restore all that he received under [the contract]” (citation omitted).

Ann & Hope, Inc. v. Muratore, 42 Mass. App. Ct. 223, 231 (1997), quoting Bellefeuille, [218]*218supra at 266. See also Walsh v.

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Cite This Page — Counsel Stack

Bluebook (online)
2009 Mass. App. Div. 215, 2009 Mass. App. Div. LEXIS 63, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcnamara-v-corte-real-massdistctapp-2009.