Red Apple Development, LLC v. Rufus Road Partners, LLC

CourtCourt of Appeals for the Fourth Circuit
DecidedJuly 19, 2024
Docket22-1224
StatusUnpublished

This text of Red Apple Development, LLC v. Rufus Road Partners, LLC (Red Apple Development, LLC v. Rufus Road Partners, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Red Apple Development, LLC v. Rufus Road Partners, LLC, (4th Cir. 2024).

Opinion

USCA4 Appeal: 22-1224 Doc: 60 Filed: 07/19/2024 Pg: 1 of 9

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 22-1224

RED APPLE DEVELOPMENT, LLC,

Plaintiff – Appellee,

v.

RUFUS ROAD PARTNERS, LLC,

Defendant – Appellant.

No. 22-1346

Plaintiff – Appellant,

Defendant – Appellee.

Appeals from the United States District Court for the Western District of North Carolina, at Charlotte. Graham C. Mullen, Senior District Judge. (3:19-cv-00157-GCM-DCK)

Argued: May 8, 2024 Decided: July 19, 2024 USCA4 Appeal: 22-1224 Doc: 60 Filed: 07/19/2024 Pg: 2 of 9

Before NIEMEYER, RUSHING, and HEYTENS, Circuit Judges.

Affirmed by unpublished opinion. Judge Rushing wrote the majority opinion, in which Judge Heytens joined. Judge Niemeyer wrote a dissenting opinion.

ARGUED: John Robert Buric, JAMES, MCELROY & DIEHL P.A., Charlotte, North Carolina, for Appellant/Cross-Appellee. Dylan Michael Bensinger, MCGUIREWOODS LLP, Charlotte, North Carolina, for Appellee/Cross-Appellant. ON BRIEF: Preston O. Odom, III, John R. Brickley, JAMES, MCELROY & DIEHL P.A., Charlotte, North Carolina, for Appellant/Cross-Appellee. Brian Kahn, Zachary L. McCamey, MCGUIREWOODS LLP, Charlotte, North Carolina, for Appellee/Cross-Appellant.

Unpublished opinions are not binding precedent in this circuit.

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RUSHING, Circuit Judge:

A jury found that Rufus Road Partners, LLC (Rufus Road) breached its contract

with Red Apple Development, LLC (Red Apple) by failing to close on a real estate

transaction. After trial, Rufus Road moved for judgment as a matter of law, which the

district court denied. We agree with the district court that the contract does not

unambiguously contradict the jury’s verdict. Accordingly, we affirm.

I.

In 2018, Rufus Road and Red Apple entered into an Agreement for Purchase and

Sale regarding a parcel of land in Lincoln County, North Carolina. The Agreement set

forth a timeline for the transaction. First, the buyer, Red Apple, would make an initial

deposit of $50,000 with the escrow agent within five days of the Agreement going into

effect. Red Apple then had a 90-day due diligence period in which to assess the property’s

suitability for its intended use. If Red Apple did not terminate the Agreement during that

time, then Red Apple had three days after expiration of the due diligence period to make

an additional deposit of $200,000. If Red Apple did not timely deliver the additional

deposit to the escrow agent, then Rufus Road had the option to terminate the Agreement

any time before Red Apple belatedly paid the additional deposit. The Agreement specified

that the closing date would be the earlier of (1) ten days after Red Apple provided Rufus

Road written notice of its intent to close or (2) thirty days after expiration of the due

diligence period.

The transaction began smoothly enough. The Agreement went into effect on

September 10, and Red Apple delivered the initial deposit to the escrow agent before the

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September 15 deadline. Before the due diligence period’s December 10 expiration date,

Red Apple informed Rufus Road on December 6 that it intended to close the transaction

within ten days. On Sunday, December 16 and Monday, December 17, Red Apple was

ready, willing, and able to close the transaction, but the parties did not close.

A month later, on January 16, 2019, Rufus Road informed Red Apple that it was

terminating the Agreement because Red Apple had not timely paid the additional deposit.

Two days after receiving this notice, Red Apple deposited the additional $200,000 with the

escrow agent, informed Rufus Road, and contested termination of the Agreement. The

parties never closed the transaction.

Red Apple subsequently sued Rufus Road for breach of contract. At trial, Red

Apple argued that Rufus Road breached the Agreement by failing to close the transaction

in December 2018 (after Red Apple gave notice of its intent to close) and again in January

2019 (after Red Apple paid the additional deposit). Rufus Road contended it was not

required to close in December 2018 because Red Apple did not pay the additional deposit

within three days of the due diligence period’s expiration, and it was not obligated to close

in January 2019 because it terminated the Agreement before Red Apple paid the additional

deposit. The jury sided with Red Apple, finding that Rufus Road had breached the

Agreement and owed Red Apple $200,000 in damages.

After the verdict, Rufus Road renewed its prior motion for judgment as a matter of

law, arguing that it had no obligation to close the transaction because Red Apple failed to

timely pay the additional deposit, which was a condition precedent to Rufus Road’s

obligations under the Agreement. The district court denied the motion. After considering

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the terms of the Agreement and the trial evidence, the court concluded the Agreement was

ambiguous as to what obligations the parties bore after Red Apple missed the deadline for

timely paying the additional deposit, and a jury reasonably could have resolved the

ambiguity in Red Apple’s favor and found Rufus Road breached the contract. Rufus Road

appealed.

II.

We review the denial of judgment as a matter of law de novo. Fontenot v. Taser

Int’l, Inc., 736 F.3d 318, 332 (4th Cir. 2013). Judgment as a matter of law may be granted

after a jury verdict “only if, viewing the evidence in a light most favorable to the non-

moving party (and in support of the jury’s verdict) and drawing every legitimate inference

in that party’s favor, the only conclusion a reasonable jury could have reached is one in

favor of the moving party.” Drummond Coal Sales, Inc. v. Norfolk S. Ry. Co., 3 F.4th 605,

610 (4th Cir. 2021) (internal quotation marks omitted); see also Fed. R. Civ. P. 50(b). To

prevail, Rufus Road “must show that there could be no breach of the Agreement under any

reasonable theory.” Drummond Coal Sales, 3 F.4th at 610.

Under North Carolina law, which governs this dispute, “a breach of contract occurs

when a party fails to perform a contractual duty which has become absolute.” Salvaggio

v. New Breed Transfer Corp., 564. S.E.2d 641, 644 (N.C. Ct. App. 2002). When a duty is

contingent upon a condition precedent, that condition “must occur before a contractual

right arises.” Powell v. City of Newton, 703 S.E.2d 723, 727 (N.C. 2010) (internal

quotation marks omitted); see also Craftique, Inc. v. Stevens & Co., 364 S.E.2d 129, 131

(N.C. 1988) (defining conditions precedent as “those facts and events, occurring

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subsequently to the making of a valid contract, that must exist or occur before there is a

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Related

Craftique, Inc. v. Stevens and Co., Inc.
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703 S.E.2d 723 (Supreme Court of North Carolina, 2010)
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Red Apple Development, LLC v. Rufus Road Partners, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/red-apple-development-llc-v-rufus-road-partners-llc-ca4-2024.