Miceli v. Helyer

671 A.2d 826, 40 Conn. App. 336, 1996 Conn. App. LEXIS 68
CourtConnecticut Appellate Court
DecidedFebruary 13, 1996
Docket13455
StatusPublished
Cited by7 cases

This text of 671 A.2d 826 (Miceli v. Helyer) is published on Counsel Stack Legal Research, covering Connecticut Appellate Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Miceli v. Helyer, 671 A.2d 826, 40 Conn. App. 336, 1996 Conn. App. LEXIS 68 (Colo. Ct. App. 1996).

Opinions

CRETELLA, J.

The plaintiffs, Diego Miceli and Theresa Miceli, appeal from the judgment for the named defendant1 rendered by the trial court in the plaintiffs’ action for breach of contract involving the sale of cer[338]*338tain residential real property. On appeal, the plaintiffs argue that the trial court improperly (1) concluded that the plaintiffs’ failure to provide a satisfactory water test report constituted the failure of a condition precedent to the contract, (2) admitted evidence regarding agency when agency was not pleaded by the defendant, and, even if properly considered, found that the plaintiffs’ broker was acting as the agent of the plaintiffs, and (3) concluded that there was a delay on the part of the plaintiffs in addressing the water problem and that extensions of the closing date were granted so that the plaintiffs could close on their new residence. We affirm the judgment of the trial court.

The trial court found the following facts. The plaintiffs and the defendant executed a contract for the sale of the plaintiffs’ house to the defendant for $456,200. The contract specified that the closing take place on or before October 1, 1988, and contained a mortgage contingency clause in the amount of $365,000. The contract also contained various addenda making the contract contingent on satisfactory water, structural, termite, septic system and radon inspections. The contract also contained a liquidated damage clause that provided for the plaintiffs to retain the $15,000 deposit of the defendant if the defendant breached the contract.

On August 12, 1988, the defendant obtained a mortgage commitment from First Federal Savings in the amount of $365,000, requiring that the closing take place on or before forty-five days from that date, or September 26, 1988. The mortgage commitment was “subject to a satisfactory well water analysis as to potability and E.D.B.” The agent with whom the plaintiffs had listed the property, Merrill Lynch Realty Company (Merrill Lynch), undertook to have the well water tested at the expense of the defendant. The test was unsatisfactory and the defendant paid the test fee in accordance with the contract.

[339]*339Although the defendant could have then rescinded the contract and had his deposit returned to him, he agreed to extend the closing to allow the plaintiffs time to correct the water problem. The bank agreed to extend the mortgage commitment date, and, notwithstanding the fact that the delay in closing would require the defendant to pay a higher interest rate on that mortgage commitment, the defendant agreed to absorb such cost. The parties agreed to extend the closing date to the end of November, 1988, so that the plaintiffs could close on the house that they were purchasing.

The parties did not reach an agreement as to who would pay the cost of any additional water tests. Merrill Lynch arranged to have successive tests performed and the reports were sent directly to the plaintiffs. The defendant never received a copy of the reports and was never asked to pay for any subsequent reports.

After several delays, the closing was scheduled for December 9, 1988, at the closing office of the bank in Glastonbury. The defendant and his wife were present on that date, as well as the defendant’s attorney and the attorney for the bank. The plaintiffs were not present but their attorney was there with appropriate pre-signed documents. As the closing commenced, the attorney for the bank requested the water report. The plaintiffs’ attorney called his office in Hartford and was told that the water test report was satisfactory and would be brought right over. The parties waited for one and one-half hours for the report to arrive. Eventually, the attorney for the bank stated that the closing could not take place that day and he left.2 The defendant, his wife and his lawyer also left. The plaintiffs’ attorney continued to wait and eventually the report arrived. The report, which was dated December 9, 1988, the [340]*340date of the closing, was addressed to the plaintiff Diego Miceli. December 9 was the last date that the closing could take place at the specified mortgage rate, which had already been increased due to the November postponement.

The plaintiffs then brought this action against the defendant alleging that they were ready, willing and able to perform the contract on December 9, 1988, and that they incurred financial losses due to the defendant’s failure to pay the purchase price and take title on that date.3 The trial court held that it was the responsibility of the plaintiffs to pay for the second water test and that the December 9 closing did not take place because the water test report was not provided. The court therefore ordered that the defendant’s $15,000 deposit held by Merrill Lynch be returned to the defendant. The plaintiffs then took this appeal.

I

The plaintiffs first argue that the trial court improperly found that their failure to supply a satisfactory water test at the closing constituted the failure of a condition precedent to the contract. The plaintiffs contend that they had no contractual obligation to produce an analysis for either the defendant or his mortgagee. They argue that although the contract provisions in question were intended to be conditions precedent to the defendant’s obligation to perform his agreement to purchase, they could not be invoked to excuse the defendant’s performance on December 9, 1988. We disagree.

We note initially that “[t]he factual findings of a trial court on any issue are reversible only if they are clearly erroneous. . . . This court cannot retry the facts or pass [341]*341upon the credibility of the witnesses. ... A finding of fact is clearly erroneous when there is no evidence in the record to support it ... or when although there is evidence to support it, the reviewing court on the entire evidence is left with the definite and firm conviction that a mistake has been committed. ...” (Citation omitted; internal quotation marks omitted.) Rosick v. Equipment Maintenance & Service, Inc., 33 Conn. App. 25, 40-41, 632 A.2d 1134 (1993).

“A condition precedent is a fact or event which the parties intend must exist or take place before there is a right to performance. ... If the condition precedent is not fulfilled the contract is not enforceable.” (Citations omitted; internal quotation marks omitted.) Luttinger v. Rosen, 164 Conn. 45, 47-48, 316 A.2d 757 (1972); see Feinberg v. Berglewicz, 32 Conn. App. 857, 860, 632 A.2d 709 (1993). It is clear that unless a satisfactory water test report was produced, the defendant had no obligation to purchase the property. The trial court found that the plaintiffs were obligated to produce the report as a condition precedent to the contract4 and that, without the report, there was no right to performance. When the condition precedent failed, the contract terminated.

According to the plaintiffs, however, the water test addendum did not require the plaintiffs to supply any documentation to the defendant. The plaintiffs argue that part b of paragraph eleven5

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Bluebook (online)
671 A.2d 826, 40 Conn. App. 336, 1996 Conn. App. LEXIS 68, Counsel Stack Legal Research, https://law.counselstack.com/opinion/miceli-v-helyer-connappct-1996.