Michael Browne v. Christopher Roth and Debra Roth

CourtCourt of Appeals of Iowa
DecidedDecember 7, 2022
Docket21-1764
StatusPublished

This text of Michael Browne v. Christopher Roth and Debra Roth (Michael Browne v. Christopher Roth and Debra Roth) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Michael Browne v. Christopher Roth and Debra Roth, (iowactapp 2022).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 21-1764 Filed December 7, 2022

MICHAEL BROWNE, Plaintiff-Appellant,

vs.

CHRISTOPHER ROTH and DEBRA ROTH, Defendants-Appellees. ________________________________________________________________

Appeal from the Iowa District Court for Black Hawk County, Bradley J.

Harris, Judge.

Michael Browne appeals the district court’s rejection of his statutory and

breach-of-contract claims against Christopher and Debra Roth for failure to

disclose material defects in their written disclosure statement. AFFIRMED.

Adam J. Babinat of Redfern, Mason, Larsen & Moore, P.L.C., Cedar Falls,

for appellant.

Patrick C. Galles of Correll, Sheerer, Benson, Engels, Galles & Demro,

P.L.C., Cedar Falls, for appellees.

Considered by Vaitheswaran, P.J., and Greer and Schumacher, JJ. 2

VAITHESWARAN, Presiding Judge.

Michael Browne bought a Cedar Falls home from Christopher and Debra

Roth, with the intent to “gut” and remodel it before moving in. While he was

stripping the basement walls, he discovered mold and moisture. Browne stopped

his demolition work and never moved into the home.

Browne sued the Roths for failure to “disclose any problems concerning

water seepage . . . [and] any known fungus or mold issues.”1 He claimed the Roths

breached statutory disclosure requirements as well as the real estate purchase

contract incorporating those requirements.2

A few months after suit was filed, a basement pipe burst. Browne

discovered the pipe on “one of [his] checkups.” Water was “[s]praying against the

drywall” and running to the floor. Browne did “not know” how long the water had

been running before he discovered it.

Years passed. The home remained unoccupied from the time of purchase

in mid-2016 through trial five years later. Following trial, the district court ruled in

favor of the Roths. In response to a posttrial motion, the court enlarged its findings

and reaffirmed its conclusions.

On appeal, Browne contends “the Roths had actual knowledge of a mold

and moisture problem,” they “failed to disclose anything which would have

informed [him] further investigation was warranted,” and “[t]he district court erred

by concluding the Roths did not violate their [statutory] disclosure duty” and by

1Browne alleged other nondisclosures that are not at issue on appeal. 2Brown additionally raised negligent and fraudulent-misrepresentation claims that he voluntarily dismissed with prejudice. 3

rejecting his contract claim. He concedes the breach-of-contract claim rises or

falls on the outcome of the statutory claim. Accordingly, we will confine our

discussion to the statutory claim.

Iowa Code chapter 558A (2021) requires a prospective seller to “deliver a

written disclosure statement to” a prospective buyer. The statement must “include

information relating to the condition and important characteristics of the property

. . . including significant defects in the structural integrity.” Iowa Code

§§ 558A.2(1), 558A.4(1)(a); Iowa Admin. Code r. 193E—14.1(6) (sample

statement); Putman v. Walther, 973 N.W.2d 857, 863 (Iowa 2022). A person who

violates the disclosure requirement is ordinarily liable for actual damages, but

“shall not be liable . . . for the error, inaccuracy, or omission in information . . .

unless that person has actual knowledge of the inaccuracy, or fails to exercise

ordinary care in obtaining the information.” Iowa Code § 558A.6(1).

We begin with the Roths’ information on water seepage. The district court

found that the Roths saw waviness in “the beadboard located in the northeast and

southeast corner of the basement.” They “removed the beadboard, and the

wallboard behind the beadboard was damp.” They removed the wallboard and

observed black mold on the wallboard, flooring strips, and the concrete block

foundation wall.” They “cleaned up the mold, caulked, replaced a piece of

wallboard in each corner with mold-resistant sheetrock, and returned the

beadboard to its original position.” The Roths do not dispute these findings. The

findings are supported by substantial evidence. See Hammes v. JCLB Props.,

LLC, 764 N.W.2d 552, 555 (Iowa Ct. App. 2008) (setting forth standard of review). 4

We turn to whether the Roths disclosed the information to Browne. The

answer is unequivocally “No.” They checked “No” to the question about “[a]ny

known water, seepage or other problems”; “No” to the question about “[a]ny known

fungus or mold”; “No” to the question about “[a]ny known modifications,

remodeling, alterations, or repairs, etc., made without necessary permits or

licensed contractors”; and “No” to the question about “[a]ny known physical

problems.” When they completed the form, they had actual knowledge of seepage

and mold in the basement. Again, the Roths conceded as much. Because

disclosure of the seepage, mold and remedial measures was statutorily required,

the Roths violated the statute by failing to make the disclosures. See Yeboah v.

Emans, No. 12-0900, 2011 WL 1453231, at *2 (Iowa Ct. App. Apr. 10, 2013).3 We

are left with the question of actual damages for the mold and water seepage.

The district court found “the mold problem in the basement of the residence

had resolved at no cost to” Browne and “[t]his had occurred despite standing water

being present on the floor of the basement for several years due to an unrelated

bursting of a water pipe.” The court concluded Browne “failed to prove any

damages to remedy the undisclosed mold problem in the basement of the

residence.”

Substantial evidence supports the court’s underlying findings. Browne

testified, “The mold is gone.” When pressed with the question, “There is no mold

3 The district court found the Roths “thought they had taken care of the problem.” The court of appeals was unpersuaded by a similar argument. See Yeboah, 2011 WL 1453231, at *3 (noting a “sunroom leak was a known problem that was repaired” and “[t]he sellers had an obligation to disclose the leak and the repair, notwithstanding their belief that the issue was resolved”). 5

there anymore?” he responded, “The last time I was there, no. There was no

mold.” And when asked, “The mold is not an issue?” He responded, “No, sir.”

Seeking reconfirmation of this point, Browne’s attorney inquired, “Are you asking

the court for any damages related to any mold remediation you would have had to

undertake?” Browne answered, “No sir.” In light of his testimony, the district court

did not err in concluding no actual damages were warranted on the statutory claim

related to nondisclosure of mold.

We turn to Browne’s requested damages for “water seepage repair.” In its

expanded posttrial findings, the district court found the “condensation problem”

observed by the Roths “would be alleviated by the construction of energy walls.”

Because the City required these walls in connection with Browne’s remodeling of

the basement, the court determined Browne “incurred no additional costs as a

result of [the Roths’] failure to disclose the moisture problem.”

We discern a more fundamental problem with Browne’s request for water-

seepage damages—the Roths’ lack of actual knowledge of widespread water

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Related

Hammes v. JCLB PROPERTIES, LLC
764 N.W.2d 552 (Court of Appeals of Iowa, 2008)
Tim O'Neill Chevrolet, Inc. v. Forristall
551 N.W.2d 611 (Supreme Court of Iowa, 1996)
Johnson v. Baum
788 N.W.2d 397 (Court of Appeals of Iowa, 2010)

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