SCOTT BAKER v. LARRY BASKIN

CourtCourt of Appeals of Tennessee
DecidedDecember 30, 2024
DocketM2023-00433-COA-R3-CV
StatusPublished

This text of SCOTT BAKER v. LARRY BASKIN (SCOTT BAKER v. LARRY BASKIN) is published on Counsel Stack Legal Research, covering Court of Appeals of Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SCOTT BAKER v. LARRY BASKIN, (Tenn. Ct. App. 2024).

Opinion

12/30/2024 IN THE COURT OF APPEALS OF TENNESSEE AT NASHVILLE April 2, 2024 Session

SCOTT BAKER ET AL. v. LARRY BASKIN ET AL.

Appeal from the Chancery Court for Davidson County No. 18-1046-I Patricia Head Moskal, Chancellor ___________________________________

No. M2023-00433-COA-R3-CV ___________________________________

Buyers of a residential home brought action against sellers for 1) breach of contract, 2) negligent misrepresentation, 3) negligence, 4) negligence per se, 5) gross negligence, 6) residential disclosures violations, and 7) fraud. The claims arise from the discovery of a sinkhole months after the sale. The sinkhole was not indicated “through the contour lines on the property’s recorded plat,” see Tenn. Code Ann. § 66-5-212(c) (2015), and the sellers insist they had no knowledge of a sinkhole on the property. For these reasons, they did not disclose the existence of the sinkhole on the Tennessee Residential Property Condition Disclosure form. Nevertheless, the proof at trial established that one of the sellers, Larry Baskin, while mowing the lawn, discovered a depression in the yard six months prior to listing the property for sale, which he believed to be caused by rotting roots from a tree that had been removed years earlier. He filled the depression with two four-by-four, pressure- treated, rot-resistant posts and topsoil. Because it was near a downspout, he also placed the plastic bag from the topsoil over the posts, which he covered with more soil and grass. The property was sold seven months later, during which time Mr. Baskin did not notice the area “concaving or dipping in any way” even though he mowed regularly over the area with his 500-pound riding mower. Following a bench trial, the court dismissed all claims except the negligence claim. Significantly, the court dismissed the claim for negligent misrepresentation because the purchase agreement contained an “as is” clause. However, the court held that Larry Baskin was liable under the claim for common law negligence, finding that he “breached the duty of reasonable care by not informing the Buyers of the existence of the hole prior to their purchase of the Property. The harm resulting from Mr. Baskin’s breach was damage to the value of the Property.” The court awarded the buyers compensatory damages of $55,000 for the diminution in value of the property. Additionally, finding the buyers to be the prevailing parties according to the purchase agreement, the trial court awarded them attorney’s fees and costs. This appeal followed, with the sellers challenging Mr. Baskin’s liability under the negligence claim and the buyers challenging the dismissal of the gross negligence claim. For the reasons explained below, we affirm the dismissal of the claim for gross negligence; however, we reverse the finding of Mr. Baskin’s liability based on the claim of negligence because “a seller’s liability for the failure to disclose such material facts in a real estate transaction is coextensive with a party’s liability for fraudulent or negligent misrepresentation.” Fayne v. Vincent, 301 S.W.3d 162, 177 (Tenn. 2009). Because we have affirmed the dismissal of the claim for gross negligence and reversed the ruling concerning the negligence claim, we also vacate the award of damages and attorney’s fees to the buyers. In that the sellers are now the prevailing parties, we remand with instructions to award the sellers the reasonable and necessary attorney’s fees and costs they are entitled to recover pursuant to the parties’ contract.

Tenn. R. App. P. 3 Appeal as of Right; Judgment of the Chancery Court Affirmed in Part, Reversed in Part, Vacated in Part, and Remanded

FRANK G. CLEMENT, JR., P.J., M.S., delivered the opinion of the court, in which D. MICHAEL SWINEY, C.J., and ANDY D. BENNETT, J., joined.

J. Ross Pepper, Nashville, Tennessee, for the appellants, Larry Baskin and Linda Baskin.

Jean Dyer Harrison, Nashville, Tennessee, for the appellees, Julie Baker and Scott Baker.

OPINION

FACTS AND PROCEDURAL HISTORY

Larry and Linda Baskin (“Sellers”) had lived at 113 Blue Hills Court (“the Property”) for thirty-two years, when in March 2017, Mr. Baskin felt a dip in the ground while riding the mower. Upon further investigation, he pulled back the grass and discovered a small hole to the side of a bush. He believed it was caused by the decay of roots from a tree that had been cut down years earlier. Because the hole was near a downspout, Mr. Baskin placed two five feet long, four-by-four pressure treated posts into the hole, placed some topsoil and the topsoil bag on top of the posts, and covered the area with more topsoil and grass.

Over the next seven months, between March and October 2017, Mr. Baskin never noticed the area “concaving or dipping in any way” even though he mowed regularly over the area with his 500-pound riding mower.1 He stated that a professional landscaper also drove over the area with commercial landscaping equipment. For these reasons, Mr. Baskin believed the matter was resolved and no further action was required.2

1 The weight was an approximation. 2 Mr. Baskin testified that he did not discuss this discovery or repair with Mrs. Baskin, and she testified that she knew nothing of the hole until this suit was filed. Significantly, the trial court found that Mrs. Baskin had no knowledge of the hole until suit was filed, and that ruling is not challenged on appeal. -2- After deciding to move closer to their family, Sellers listed the home for sale on September 8, 2017, for the price of $329,900. In the process, they provided a Tennessee Residential Property Condition Disclosure form, which contained a “sinkhole” question:

Is a sinkhole present on the property? A sinkhole is defined pursuant to Tenn. Code Ann. § 66-5-212(c) as “a subterranean void created by the dissolution of limestone or dolostone strata resulting from groundwater erosion, causing a surface subsidence of soil, sediment, or rock and is indicated through the contour lines on the property’s recorded plat map.”

Sellers checked the box “no.” In response to the question if there were any “other soil problems,” Sellers again checked the “no” box.

Four days later, Scott and Julie Baker (“Buyers”) made an offer to purchase the Property. The purchase and sale agreement contained a sinkhole provision: “16. Seller’s Additional Obligations. If Seller has any knowledge of an exterior injection well, a sinkhole as defined pursuant to Tenn. Code Ann. § 66-5-212(c) . . . , Seller shall be obligated to counter this offer by disclosure of the existence of the above.” Sellers counter-offered with several conditions, one of which stated, “Buyer[s’] obligations are subject to a home inspection, but the property is purchased as is.” Buyers responded in “Counter Offer #2,” acknowledging, “Sale of home is contingent on a satisfactory home inspection. Buyers are aware that home is being sold ‘as is.’” During the negotiation process, Buyers also signed a disclaimer notice that advised them to, among other things, seek the advice of a geotechnical engineer to determine the risk of sinkholes. Buyers performed a home inspection, which revealed nothing remarkable, and the parties closed on October 20, 2017. The final purchase price was $329,900.

Mr. Baker, one of the Buyers, testified that no issues were noted with the Property during the fall of 2017 or the winter of 2018. However, that spring, while Mr.

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SCOTT BAKER v. LARRY BASKIN, Counsel Stack Legal Research, https://law.counselstack.com/opinion/scott-baker-v-larry-baskin-tennctapp-2024.