MPI SC v. Levy Center

CourtCourt of Appeals of South Carolina
DecidedFebruary 16, 2011
Docket2011-UP-065
StatusUnpublished

This text of MPI SC v. Levy Center (MPI SC v. Levy Center) is published on Counsel Stack Legal Research, covering Court of Appeals of South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
MPI SC v. Levy Center, (S.C. Ct. App. 2011).

Opinion

THIS OPINION HAS NO PRECEDENTIAL VALUE.  IT SHOULD NOT BE CITED OR RELIED ON AS PRECEDENT IN ANY PROCEEDING EXCEPT AS PROVIDED BY RULE 268(d)(2), SCACR.

THE STATE OF SOUTH CAROLINA
In The Court of Appeals

MPI South Carolina - 1, LLC, Appellant,

v.

Levy Center, LLC, Boyd Capital, LLC,  The Savannah Bank, and The McNair Law Firm, P.A., Respondents.


Appeal From Jasper County
Marvin H. Dukes, III, Master-In-Equity


Unpublished Opinion No.  2011-UP-065 
Submitted December 1, 2010 – Filed February 16, 2011


AFFIRMED


Steven L. Smith, of Charleston, for Appellant.

Jeffrey S. Tibbals, of Charleston, and William B. Harvey, III, of Beaufort, for Respondents.

PER CURIAM:  MPI South Carolina-1, LLC (MPI) appeals from an order granting Levy Center, LLC, and Boyd Capital, LLC's (collectively, Respondents) motion for summary judgment, arguing the master-in-equity erred in (1) ruling that unforeseen changes in zoning regulations did not make performance of the contracts impossible; (2) concluding the change in property regulations did not excuse its obligations of performance under the doctrine of frustration of purpose; and (3) granting summary judgment because genuine issues of material fact exist concerning the degree of Respondents' involvement with the planned development.  We affirm.[1]

FACTS

MPI is a South Carolina land development firm that contracted with Levy Center to purchase a piece of land (Levy Tract).[2]  Levy Center (Levy) owned the property, but Boyd Capital (Boyd) had a purchase contract, which it assigned to MPI on March 17, 2006.[3]  Boyd completed some preliminary development work on the Levy Tract before it assigned its contract with Levy to MPI, including due diligence and design of the development.  While MPI was continuing the due diligence and design work, Jasper County enacted a temporary building moratorium on "all land development as well as on commercial construction that was greater than 10,000 [square feet] or produced heavy amounts of traffic."  Jasper County intended for the moratorium to last from July 2006 to November 13, 2007; however, on November 13, 2007, the County amended the zoning in the area where the Levy Tract was located.  The new zoning requirements mandated a certain lot size that, according to MPI, had the practical effect of making its intended development impossible.

MPI filed a declaratory judgment action on May 11, 2007, seeking rescission of the contract and a full refund of the payments it made into escrow because the contract had failed its essential purpose and was impossible to perform.[4]  In their Answers, Levy and Boyd alleged MPI was in breach of the contract for failing to make payments on the property before the closing date in November 2006.  Boyd also alleged the assignment agreement provided all amounts paid by MPI to Boyd for the assignment were non-refundable regardless of whether MPI closed on the property.  Levy and Boyd both filed motions for summary judgment, which the master granted on February 19, 2009, after a hearing on the matter.  This appeal followed.   

STANDARD OF REVIEW

When reviewing the grant of a summary judgment motion, the appellate court applies the same standard that governs the trial court under Rule 56(c), SCRCP, which provides summary judgment is proper when there is no genuine issue as to any material fact and the moving party is entitled to judgment as a matter of law.  Fleming v. Rose, 350 S.C. 488, 493, 567 S.E.2d 857, 860 (2002).  On appeal from an order granting summary judgment, the appellate court reviews all ambiguities, conclusions, and inferences arising in and from the evidence in a light most favorable to the non-moving party below.  Willis v. Wu, 362 S.C. 146, 151, 607 S.E.2d 63, 65 (2004). 

LAW/ANALYSIS

I.  Impossibility of Performance

MPI argues the master erred in ruling that unforeseen changes in zoning regulations did not make performance of the contracts impossible.  MPI also argues the master erred in granting summary judgment because there was substantial evidence that the parties were working together toward the same goal, and it was immaterial that the parties did not include the purpose in the contract.  We disagree.

MPI admits the documents did not contain an express provision that specifically stated the purpose of the contract was to develop the Levy Tract in a specific manner; however, it asserts the doctrine of impossibility of performance does not rest exclusively on the language of the contract.  MPI maintains the doctrine has been "extended to include situations in which performance as anticipated is not merely physically impossible, but so impracticable as to significantly alter the understanding of the parties as to the nature of the underlying contract."  It further states the occurrence must be unexpected, but it does not have to be unforeseeable.  MPI claims the "imposition of a building moratorium, and the significant changes in zoning, were unforeseeable events, the non-occurrence of which were implicit conditions of the contract."

In Hawkins v. Greenwood Development Corp., 328 S.C. 585, 593, 493 S.E.2d 875, 879 (Ct. App. 1997), this court held a party to a contract must perform its obligations under the contract unless its performance is rendered impossible by an act of God, the law, or by a third party, and impossibility must be real and not a mere inconvenience.  "A party to a contract cannot be excused from performance on the theory of impossibility of performance unless it is made to appear that the thing to be done cannot by any means be accomplished, for if it is only improbable or out of the power of the obligor, it is not deemed in law impossible."  Id. (quoting 17A Am. Jur. 2d Contracts § 673, at 681 (1991)). 

Also, in Coker International, Inc. v. Burlington Industries, Inc., 747 F. Supp. 1168, 1170 (D.S.C. 1990), aff'd, 935 F.2d 267 (4th Cir. 1991), the district court held that "[s]ubjective impossibility of performing does not relieve a party from the contract unless the contract so states."  Further, in Opera Co. of Boston v. Wolf Trap Foundation for Performing Arts, 817 F.2d 1094, 1102 (4th Cir.

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