Reily v. Dekelbaum

CourtSuperior Court of Maine
DecidedAugust 30, 2019
DocketKENre-18-11
StatusUnpublished

This text of Reily v. Dekelbaum (Reily v. Dekelbaum) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Reily v. Dekelbaum, (Me. Super. Ct. 2019).

Opinion

(

STATE OF MAINE SUPERIOR COURT KENNEBEC, ss CIVIL ACTION DOCKET NO. RE-18-11

CHRISTOPHER REILY and KIMBERLY REILY

Plaintiffs ORDER GRANTING DEFENDANT'S MOTION FOR SUMMARY JUDGMENT v.

SHERYL DEKELBAUM,

Defendant.

Before the court is defendant Sheryl Dekelbaum's motion for summary judgement on

counts II and IV of plaintiff Christopher Reily's complaint. The court previously dismissed counts

I and III of the complaint on October 3, 2018. Plaintiff Reily is represented by Susan Farnsworth

and defendant Dekelbaum is represented by Brian D. Condon Jr. Oral argument was held on

August 6, 2019. For the following reasons, the court grants defendant Dekelbaum's motion.

In June 2017, Dekelbaum listed property located at 289 Stanley Road, Winthrop, Maine

for sale with her broker Eben Thomas. (Def.'s SMF, 1.) In her Property Disclosure Statement

Dekelbaum noted the existence of known defects in the property including the existence of "water,

moisture or leakage;" "prior water, moisture or leakage;" and the presence of a sump pump. (Def.'s

SMF' 2; Pl.'s SMF' 29.) The disclosure statement also noted that there is "some leakage in spring

and heavy rain." (Def.'s SMF' 2; Pl.'s SMF! 29.)

On June 17, 2017 Reily visited the property along with his real estate agent, Brandon

Caruso. (Def.' s SMF ! 3 .) The same day, Caruso sent Thomas an email explaining that his clients

1 were interested in the property and would like to arrange a second showing. (Def.'s SMF, 4.) The

next day, Caruso sent Thomas another email asking "what cause the basement to flood, do the

cracks foundation seep water year round, and did homeowners seal the ties and the foundation

walls as they were leaking as well or just to patch." (Def.'s SMF j 6; Pl.'s SMF j 30.) According

to Dekelbaum, Thomas never answered Caruso's inquiry about the cause of the basement flooding

and what work had been done to fix the basement water problems. (Def.'s SMF, 8.) According

to Reily, Caruso told Reily that Thomas told Caruso that "a lot of work had been done in the

basement and the water issue had been taken care of." (Pl's SMF ,, 8, 32.)

On June 21, 2017, Dekelbaum accepted Reily' s offer to purchase the property for

$250,000. (Def.'s SMF' 11.) The agreement gave Reily ten days to inspect the property. (Def.'s

SMF, 11.) If the results of the inspection were unsatisfactory, Reily could back out of the contract.

(Def.'s SMF' 20.) On June 25, 2017, Southern Maine Inspection Services completed an inspection

of the property. (Def.' s SMF, 12.) The inspection report notes that "water enters into the basement

causing mold growth on sheet rock in the basement and stored items." (Def.'s SMF, 12.) The

inspector recommended "having a foundation water proofing contractor install an interior

foundation drain system to prevent future water entry." (Def.'s SMF ! 12.)

On June 26, 2017, Reily requested to modify the purchase and sale agreement by requiring

Dekelbaum to pay $6,000 in closing costs. (Def.' s SMF, 15 .) On June 28, 2017, Reily emailed

Caruso stating that "[Dekelbaum] is lucky we only want all of closing costs" that Dekelbaum's

basement moisture mitigation efforts had "fail[ed] miserably," and that "We just had no idea how

badly [the moisture mitigation] was failing until inspection. (Def.'s SMF, 17 .) On June 30, 2017,

Dekelbaum agreed to pay the closings costs. (Def.'s SMF, 18.) Reily and Dekelbaum closed on

2 the sale of the property in July 2017. (Def.'s SMF! 19.) After the sale, Reily suffered a basement

flood at the property during a period of heavy rains in October 2017. (Def.'s SMF! 26.)

Standard of Review

"[S]ummary judgment is appropriate when the portions of the record referenced in the

statements of material fact disclose no genuine issues of material fact and reveal that one party is

entitled to judgment as a matter of law." Currie v. Indus. Sec., Inc., 2007 ME 12, ! 11,915 A.2d

400. "A material fact is one that can affect the outcome of the case, and there is a genuine issue

when there is sufficient evidence for a fact finder to choose between competing versions of the

fact." Lougee Conservancy v. City-Mortgage, Inc., 2012 ME 103, ! 11, 48 A.3d 774 (quotation

omitted). "A plaintiff may avoid a summary judgment for the defendant as a matter of law on a

given claim by establishing a prima facie case for each element of the claim for which the plaintiff

will bear the burden of proof at trial." Binette v. Dyer Library Ass'n, 688 A.2d 898, 902 (Me.

1996). A defendant's motion for summary judgment is properly granted if "the evidence favoring

the plaintiff is insufficient to support a verdict for the plaintiff as a matter of law." Curtis v. Porter,

2001 ME 158, ! 7, 784 A.2d 18.

Discussion

"To withstand [Dekelbaum's] motion for summary judgment on fraud, [Reily is] required

to establish a prima facie case for the five elements of fraud by clear and convincing evidence."

Flaherty v. Muther, 2011 ME 32, ! 45, 17 A.3d 640. The essential elements of fraud are:

(1) that one party made a false representation; (2) of a material fact; (3) with knowledge of its falsity or in reckless disregard of whether it is true or false; (4) for the purpose of inducing another party to act in reliance upon it; and (5) the other

3 party justifiably relied upon the representation as true and acted upon it to its damage."

Id.

Reily's claim of fraud is based upon what he alleges to be Dekelbaum's intentional

misrepresentation that the basement flooding had been remedied. At common law, a seller of

property has no duty to disclose known defects in property unless there exists a special relationship

with the buyer. Stevens v. Bouchard, 532 A.2d 1028, 1030 (Me. 1987). Statutory law, however,

requires a seller of residential real property to disclose known defects to the purchaser. 33 M.R.S.

§ 173(5) (2017). Such a disclosure is neither a warranty by the seller nor intended to be part of any

contract between the purchaser and the seller. Id. § 176(1). Further, the property disclosure

statement may not be used as a substitute for an inspection and does not obviate the purchaser's

obligation to inspect the physical condition of the property. Id. § 176(2).

In this case, there is no genuine issue regarding the material facts of whether Dekelbaum

made a false representation upon which Reily justifiably relied. Reily's only evidence that

Dekelbaum made a representation that the basement water issue had been remedied is his own

statement that Caruso told him that Thomas had said that the water issue had been taken care of.

This evidence, however, is inadmissible hearsay because its is an out of court statement made by

Caruso that is being offered to prove that it is true that Dekelbaum, through her agent, made a

representation that the water issue had been remedied. M.R. Evid. 801 & 802. Although it would

be admissible as an opposing party statement if Caruso testified that Thomas had told him the

water issue was taken care of, Caruso could not recall Thomas making any such statement at his

deposition. (Caruso Depo.

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Related

Currie v. Industrial Security, Inc.
2007 ME 12 (Supreme Judicial Court of Maine, 2007)
Curtis v. Porter
2001 ME 158 (Supreme Judicial Court of Maine, 2001)
Chapman v. Bomann
381 A.2d 1123 (Supreme Judicial Court of Maine, 1978)
Binette v. Dyer Library Ass'n
688 A.2d 898 (Supreme Judicial Court of Maine, 1996)
Stevens v. Bouchard
532 A.2d 1028 (Supreme Judicial Court of Maine, 1987)
Flaherty v. Muther
2011 ME 32 (Supreme Judicial Court of Maine, 2011)
Lougee Conservancy v. Citimortgage, Inc.
2012 ME 103 (Supreme Judicial Court of Maine, 2012)

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Reily v. Dekelbaum, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reily-v-dekelbaum-mesuperct-2019.