Ray M. Ward and Mary K. Ward v. Marilyn Denise Cranford

CourtCourt of Appeals of Mississippi
DecidedAugust 24, 2021
Docket2020-CA-00410-COA
StatusPublished

This text of Ray M. Ward and Mary K. Ward v. Marilyn Denise Cranford (Ray M. Ward and Mary K. Ward v. Marilyn Denise Cranford) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ray M. Ward and Mary K. Ward v. Marilyn Denise Cranford, (Mich. Ct. App. 2021).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2020-CA-00410-COA

RAY M. WARD AND MARY K. WARD APPELLANTS

v.

MARILYN DENISE CRANFORD APPELLEE

DATE OF JUDGMENT: 01/07/2020 TRIAL JUDGE: HON. JOSEPH KILGORE COURT FROM WHICH APPEALED: CHOCTAW COUNTY CHANCERY COURT ATTORNEYS FOR APPELLANTS: KELSEY LEIGH DISMUKES J. LANE GREENLEE ATTORNEY FOR APPELLEE: JAY HOWARD HURDLE NATURE OF THE CASE: CIVIL - CONTRACT DISPOSITION: REVERSED AND REMANDED - 08/24/2021 MOTION FOR REHEARING FILED: MANDATE ISSUED:

BEFORE WILSON, P.J., GREENLEE AND WESTBROOKS, JJ.

WILSON, P.J., FOR THE COURT:

¶1. Marilyn Cranford entered into a lease-purchase agreement to buy a house from Ray

and Mary Ward. The lease term was three years, and the contract gave Cranford an option

to buy the property “at any point during the term of [the] lease for the sum of $44,000.00.”

The contract also provided that “$400.00 of [each] monthly lease payment shall be credited

against the purchase price.” Near the time the contract was executed, Cranford paid the

Wards a total of $20,000 by three separate checks. Two of the checks were dated ten days

prior to the parties’ contract, and the third was dated the same day as the contract. However,

the contract itself made no mention of the $20,000. ¶2. Prior to the end of the three-year lease term, Cranford notified the Wards that she

intended to exercise her purchase option. Cranford tendered a cashier’s check of $9,600,

which she stated was the remaining balance due after deducting her initial payments totaling

$20,000 and $14,400 credit for monthly rent payments. The Wards rejected Cranford’s

check, asserting that her initial payments totaling $20,000 did not count toward the purchase

price. Cranford then filed suit for specific performance, and the Wards answered and filed

a counterclaim for ejectment. After a trial, the chancellor held that the contract was

unambiguous, that the purchase price for the property was $44,000, and that Cranford validly

exercised the purchase option by tendering the balance due of $9,600. The chancellor

granted specific performance and ordered the Wards to deed the property to Cranford.

¶3. On appeal, the Wards argue that the parties’ contract is unambiguous and that the

chancellor misapplied the “four corners doctrine.” They further argue that the chancellor

improperly considered parol evidence by ruling that Cranford’s initial payments totaling

$20,000 counted toward the purchase price. Finally, they argue that the chancellor erred by

ordering specific performance and that Cranford should have been ejected.

¶4. We conclude that the parties’ contract is ambiguous and unclear with respect to

whether Cranford’s initial payments totaling $20,000 should be counted toward the purchase

price. Therefore, the chancellor erred by holding that the contract was unambiguous. We

reverse and remand for the chancellor to consider all relevant evidence, including parol or

extrinsic evidence; to make findings of fact as to the parties’ intent regarding the disputed

$20,000; and to grant appropriate relief.

2 FACTS AND PROCEDURAL HISTORY

¶5. Cranford contacted Mary K. Ward (“Kathy”) about an advertisement that Kathy had

posted on Facebook about a home for sale in Ackerman. Cranford testified that Kathy agreed

to enter into a lease-purchase contract because Cranford needed to move quickly but could

not secure financing. Cranford and the Wards later signed a lease-purchase contract with a

three-year lease term and a monthly rent of $550. In addition, Cranford was required to pay

for insurance and property taxes.1 If Cranford failed to make any payment required by the

lease within thirty days after the payment became due, the Wards had the right to terminate

the lease and retake possession.2 The contract included the following purchase option:

Option to Purchase: Lessor hereby grants to Lessee an option to purchase the . . . property at any point during the term of this lease for the sum of $44,000.00. $400.00 of the monthly lease payment shall be credited against the purchase price. Lessee may make additional payments during the term of this lease against the option price. Should Lessee’s [sic] exercise their [sic] option to purchase, Lessor shall convey the property to Lessee via special warranty deed.

In the event Lessee is unable or should not exercise this option to purchase, Lessee shall not be entitled to a refund of any of the rental paid, nor shall they be entitled to any payment for the improvements or repairs made to the property.

¶6. At trial, the Wards’ attorney asked Cranford whether Kathy ever expressed a

preference for an outright sale rather than a lease with an option to purchase. Cranford’s

attorney objected that Kathy’s preference was “inadmissible parol evidence and beyond the

1 Cranford paid the Wards $78 per month for insurance, so her actual monthly check to the Wards was $628. Cranford paid the property taxes directly to the county. 2 The contract did not grant Cranford a right to terminate.

3 four corners of the [contract].” The chancellor sustained the objection but allowed the

Wards’ attorney to make a proffer. The attorney proffered that Kathy “preferred . . . an

outright sale of the property, but in order to help . . . Cranford, she did agree to lease with

option to purchase.”

¶7. Cranford testified that she understood that if she did not exercise the purchase option,

she would not be entitled to a refund of any rent payments she had made. She said that she

was okay with that because $550 per month was a reasonable rent. Cranford denied that she

signed any other document related to the lease or purchase of the property. The Wards’

attorney showed Cranford what the Wards claimed was a preliminary handwritten agreement

with a sale price of $64,000. The handwritten document stated in full:

March 2015 $64,000 Balance (Without my storage) She may use it while it is on her property. A contract of her home will be drawn up. Denise Cranford Mary K. Ward

Kathy subsequently testified that the “Balance” was the agreed upon purchase price. Kathy

said the “storage” was a barn on the property. According to Kathy, her husband planned to

move the barn from the property, but they permitted Cranford to make use of it until it was

moved. However, Cranford testified that she did not recognize the document, and she denied

that the signature on the document was hers.

¶8. Cranford testified that she always intended to buy the house and that she paid $20,000

down toward the purchase price at the outset of the lease period. Her down payment

4 consisted of three checks:

• a $5,000 check (#5443) that Cranford signed on March 3, 2015, which posted on March 5;

• another $5,000 check (#5444) that Cranford signed on March 3, 2015, which posted on March 16; and

• a $10,000 check (#5446) that Cranford signed on March 13, 2015—the same day as the parties’ contract—which posted on March 19.

Cranford testified that these payments were “to go towards the purchase of the house.”

¶9. Over the course of the three-year lease term, Cranford made all monthly rent

payments,3 and on March 8, 2018, she sent the Wards a letter notifying them of her intent to

exercise the purchase option. The letter stated in part, “I have paid $20,000 in 2015 and

since that time I have paid $14,400 as per the contract[4] leaving a balance of $9,600 in

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Ray M. Ward and Mary K. Ward v. Marilyn Denise Cranford, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ray-m-ward-and-mary-k-ward-v-marilyn-denise-cranford-missctapp-2021.