Real Estate World, Inc. v. Southeastern Land Fund, Inc.

224 S.E.2d 747, 137 Ga. App. 771, 1976 Ga. App. LEXIS 2599
CourtCourt of Appeals of Georgia
DecidedJanuary 19, 1976
Docket51080
StatusPublished
Cited by9 cases

This text of 224 S.E.2d 747 (Real Estate World, Inc. v. Southeastern Land Fund, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Real Estate World, Inc. v. Southeastern Land Fund, Inc., 224 S.E.2d 747, 137 Ga. App. 771, 1976 Ga. App. LEXIS 2599 (Ga. Ct. App. 1976).

Opinions

Pannell, Presiding Judge.

Plaintiff-seller brought an action against the defendant-buyer for an alleged breach of a real estate [772]*772sales contract. Plaintiff sought to recover $45,000 plus interest and attorney fees upon a promissory note referred to in the contract (executed on October 12, 1972) as "additional earnest money represented by a promissory note” to be delivered by purchaser to seller "on or before November 6, 1972.” Paragraph 13 of the contract reads: "In the event purchaser defaults thereunder after having paid the additional earnest money required by Paragraph 3 hereof, [the execution and delivery of the note was considered payment of the additional earnest money] seller shall be entitled to retain all original earnest money paid hereunder as partial liquidated damages occasioned by such default, to collect the proceeds of the indebtedness owed by purchaser as additional earnest money as further partial liquidated damages occasioned by such default, and to pursue any and all remedies available to him at law or equity, including but not limited to, an action for specific performance of this contract.” The purchase price was $1,445,200, for a tract of land of approximately 3,613 acres.

The seller agreed to convey "a marketable fee simple title” with any issue of marketability to be determined "in accordance with Georgia law as supplemented by the Title Standards of the State Bar of Georgia.” See Code Ann. Ch. 85-2 Appendix, Title Standards. The seller would have until the date of closing to satisfy all valid objections with affidavits or other title papers to cure such defect. Purchaser and seller agreed to submit any dispute as to validity of title to the then existing Title Practices Committee of the State Bar of Georgia Real Property Law Section.

The purchaser was given until November 20, 1972, "to examine title and to advise Seller in writing of objections affecting the marketability of said title.” Any written notice required by the contract "shall be mailed by Registered or Certified United States Mail, return receipt requested, to the Seller at the following address: c/o James W. McRae; Troutman, Sanders, Lockerman & Ashmore...” Mr. McRae is an attorney at law in the firm of Troutman, Sanders, Lockerman & Ashmore. An affidavit of Mr. Frank W. Armstrong, attorney for défendant, in opposition to the plaintiffs motion for [773]*773summary judgment stated that he went to Atlanta, Georgia to the law offices of Troutman, Sanders, Lockerman & Ashmore on or about November 6, 1972, and spoke with Mr. McRae about the difficulty in abstracting the title to such a large tract of land during the allotted time. He stated that Mr. McRae advised him that "his associate Mr. Rowe was cognizant of all title matters pertaining to the tract of land” and Mr. Armstrong "should discuss all title matters with Mr. Rowe.” Mr. Armstrong received the information from Mr. Rowe and proceeded to abstract the title to the land in question.

On the final day for examination of title, November 20, 1972, Mr. Armstrong hand-carried a letter to Mr. Rowe in which he stated "we are having difficulty with the chain of title to land lot 71... We are going to endeavor to contact Mr. Pinson today regarding this problem, and we will let you know what he has to say. In the meantime, please let us know if you think we have incorrectly interpreted these deeds, and what action you think appropriate to remedy this difficulty.” Mr. Rowe responded on November 24, 1972 with his opinion as to the sufficiency of "evidence of marketability of the title” notwithstanding the points raised by the attorney of the defendant. In addition, he advised Mr. Armstrong that a named title insurance company had issued a policy insuring the land in question, without exception, and "will issue Owner’s Title Insurance, without exception to same, to your client.” On the appointed day for closing, defendant did not appear. Plaintiff sued, moved for and was granted summary judgment. Defendant’s motion for summary judgment and counterclaim for return of the earnest money were denied and overruled. Defendant appeals to this court enumerating as error the granting of summary judgment for plaintiff, and denial of summary judgment and counterclaim of defendant, alleging that there was an issue of material fact as to whether the contract provision relied upon to grant the motion for summary judgment was a penalty provision and void under Georgia law. Defendant further alleged that the plaintiff breached the contract and defaulted on his obligation to furnish marketable title or at least there was [774]*774an issue of material fact as to whether or not defendant had defaulted which should have been submitted to a jury. Held:

1. This action portrays two corporate real estate entities, represented by attorneys at law, who entered into a very detailed contract which set forth explicitly the rights, liabilities, and acts to be performed by each of the parties. We do not find the letter from the attorney for the defendant to an associate of the law firm representing the plaintiff, to be in full compliance with the specific provisions of the contract. A hand-carried communication, to an associate of a designated representative, regarding "difficulty with the chain of title” to 70 acres of land of a total acreage of 3,613 — asking for an opinion of that associate, and indicating continuance of action by his office with a third party, does not qualify as notice of a defect of title, or objection, raising an issue of marketability of title which would defer a sale of realty of this magnitude. The letter was not mailed by registered or certified mail, or addressed to the person, specified by the contract. Neither did it place plaintiff on notice of a defect of title affecting marketability, nor request specific action of plaintiff to remedy such purported defect. Neither the word "objection” nor the phrase "marketability of title” was mentioned in the letter. No reference was made to compliance with the contract provisions as to notice of lack of marketability of title, nor did it request reference to the State Bar Title Practice Committee in the event plaintiff did not satisfy defendant’s objection to the "difficulty with the chain of title” to the 70 acres. The failure to comply with an essential condition in the contract and the failure to appear at the place and time designated for closing of the contract amounts to a breach, where — as here, these acts were without legal excuse on his part, and there was no fault of the opposite party. Douglas v. McNabb Realty Co., 78 Ga. App. 845 (3) (b) (52 SE2d 550).

2. Defendant contends that the provisions for retention of the earnest money of $5,000 and the $45,000 promissory note were penalties, therefore void and unenforceable. They argue that for these provisions to [775]*775stand as liquidated damages, the parties must intend for them to "liquidate the damages, rather than provide a security for performance in addition to damages.” (Emphasis supplied.) They allege that the wording of the contract, i. e. "seller shall. . . retain all original earnest money [$5,000.00] paid hereunder as partial liquidated damages . . . collect the proceeds of the indebtedness [$45,000.00]. . . as further partial liquidated damages . .., and . . . pursue any and all remedies at law or equity including, but not limited to, an action for specific performance of this Contract” (emphasis supplied), permits plaintiff to recover $50,000 as partial liquidated damages and sue for specific performance and

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Real Estate World, Inc. v. Southeastern Land Fund, Inc.
224 S.E.2d 747 (Court of Appeals of Georgia, 1976)

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Bluebook (online)
224 S.E.2d 747, 137 Ga. App. 771, 1976 Ga. App. LEXIS 2599, Counsel Stack Legal Research, https://law.counselstack.com/opinion/real-estate-world-inc-v-southeastern-land-fund-inc-gactapp-1976.