Shane Criddle, et ux v. Flatworks LLC

CourtCourt of Appeals of Washington
DecidedApril 23, 2024
Docket39726-2
StatusUnpublished

This text of Shane Criddle, et ux v. Flatworks LLC (Shane Criddle, et ux v. Flatworks LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shane Criddle, et ux v. Flatworks LLC, (Wash. Ct. App. 2024).

Opinion

FILED APRIL 23, 2024 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

SHANE CRIDDLE, and TARA ) No. 39726-2-III CRIDDLE, individually and as a marital ) community, ) ) Respondents, ) ) v. ) ) FLATWORKS LLC, a Washington ) limited liability company; AMERICAN ) CONTRACTORS INDEMNITY ) UNPUBLISHED OPINION COMPANY (Bond Account No. ) 100132697), a California Corporation, ) ) Defendants, ) ) JUSTIN WOODROW GLENN, an ) individual and JANE DOE GLENN, an ) individual and jointly as a marital ) community, ) ) Appellants. )

LAWRENCE-BERREY, C.J. — Justin Glenn appeals the trial court’s order denying

various forms of postjudgment relief. The trial court denied relief because Glenn’s

motion was untimely—filed 14 days after entry of judgment. No. 39726-2-III Criddle v. Flatworks

Glenn argues his motion was timely, or alternatively, the trial court erred by not

extending the time for filing his motion. His arguments are inconsistent with controlling

authority. We affirm the trial court and, in accordance with RCW 19.86.090, award

Shane Criddle and Tara Criddle their costs on appeal, including their reasonable attorney

fees.

FACTS

Shane and Tara Criddle filed suit against Flatworks, LLC, Justin Woodrow Glenn,

Jane Doe Glenn, and American Contractors Indemnity Company. The claims relate to

construction work Flatworks failed to perform or performed improperly, despite

assurance to the Criddles.

The case was tried to a jury, which returned verdicts in favor of the Criddles and

against Glenn for unjust enrichment, negligent misrepresentation, conversion, and

violation of chapter 19.86 RCW, the Consumer Protection Act. The jury awarded

$42,430.66 in damages.

Following trial, the Criddles moved for entry of judgment on the verdict pursuant

to CR 54(e). On February 24, 2023, the trial court held a hearing on the motion. At the

hearing, defense counsel opposed entry of judgment, arguing (1) the trial court was

required to enter findings of fact and conclusions of law, (2) the Criddles failed to

substantially prevail on their claims, (3) the Criddles’ request for attorney fees was

2 No. 39726-2-III Criddle v. Flatworks

disproportionate to the claims they prevailed on, and (4) the motion was not called in

ready under former LCR 40(b)(9)(E) (2022).

The trial court took the motion under advisement and told the parties it would

expedite its review and enter judgment so the parties could file any posttrial motions.

The court explained that any posttrial motions could be filed once it entered the

judgment.

On February 27, the trial court entered a letter decision and judgment in

accordance with CR 54 and CR 58, and mailed courtesy copies to the parties. On

February 28, counsel for Glenn checked the court records online and learned that an

“order” had been entered the day before and requested a copy of it from the clerk’s

office. Clerk’s Papers (CP) at 107.

On March 13, 14 days after entry of judgment, Glenn filed a “Motion for

Judgment Notwithstanding the Verdict, Reconsideration, and Other Relief” pursuant to

CR 50(b) and CR 59. CP at 1-54. The Criddles responded to the motion, arguing in part,

that it was untimely and abandoned because it was filed 4 days after the 10-day deadline

prescribed by CR 50(b) and CR 59. The trial court denied the motion as untimely.

Glenn appeals.

3 No. 39726-2-III Criddle v. Flatworks

ANALYSIS

SERVICE OF JUDGMENT & POSTTRIAL MOTION DEADLINES

Glenn contends (1) he was entitled to an extension of time for filing his motion, or

alternatively, (2) the trial court was obligated to serve the judgment on the parties, thus

adding 3 days in accordance with CR 6(e) to his 10-day time line for filing his motion.

We disagree.

Standard of review

The application of court rules to a particular set of facts is a question of law that

we review de novo. In re Firestorm 1991, 129 Wn.2d 130, 135, 916 P.2d 411 (1996);

Brower v. Pierce County, 96 Wn. App. 559, 562, 984 P.2d 1036 (1999).

1. The trial court could not extend the filing deadline

CR 50 governs motions for judgment as a matter of law in jury trials. A CR 50(b)

motion must be filed “no later than 10 days after entry of judgment.” CR 59 governs new

trials, reconsideration, and amendment of judgments. A CR 59 motion “shall be filed not

later than 10 days after entry of the judgment.” CR 59(b).

Judgments shall be deemed entered for all procedural purposes from the time of

delivery to the clerk for filing. CR 58(b). Postjudgment motions must be filed within the

prescribed 10-day deadline after entry of judgment, otherwise they are untimely and

abandoned. See In the Matter of the Welfare of Cole, 15 Wn. App. 460, 461-63, 550 P.2d

4 No. 39726-2-III Criddle v. Flatworks

23 (1976) (applying CR 59(b)’s former 5-day deadline). Nothing in the rules required the

court to serve the judgment on the parties. Thus, Glenn’s deadline for filing his

postjudgment motion was March 9, four days before his March 13 filing.

CR 6(b) permits courts to extend time lines imposed by the civil rules for cause,

but expressly prohibits extensions of time for the taking of any action under CR 50,

CR 52, CR 59, and CR 60. See Moore v. Wentz, 11 Wn. App. 796, 799, 525 P.2d 290

(1974). Because the trial court could not extend the rules’ 10-day limit, we conclude it

did not err in determining that the motion was untimely.

2. The CR (6)(e) three-day mailing extension did not apply

Glenn argues the trial court should have added 3 days to the 10-day time line in

accordance with CR 6(e) because it served the judgment on the parties by mail. He

argues that because the 13th day fell on a Sunday, his filing of the motions on the

following Monday was timely. We disagree with both arguments.

CR 6(e) provides:

Additional Time After Service by Mail. Whenever a party has the right or is required to do some act or take some proceedings within a prescribed period after the service of a notice or other paper upon the party and the notice or paper is served upon the party by mail, 3 days shall be added to the prescribed period.

5 No. 39726-2-III Criddle v. Flatworks

By its plain language, CR 6(e) applies only when a party has a right to do some act

“after the service of a notice or other paper.” As noted previously, the judgment was

effective upon filing and nothing in the rules required it to be served on the parties.

Even were we to decide this first argument in Glenn’s favor, he would lose his

second argument. The third day after entry of the February 27 judgment was March 2.

Ten days after March 2 was March 12. March 12 was a Sunday. The rule that permits a

deadline to extend to the next day that is not a weekend or holiday applies only to actions

that must be taken within 7 days. CR 6(a). That rule has no application here, to the 10-

day rules. Even were we to add 3 days for mailing, because Glenn failed to file his

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Related

Holland v. City of Tacoma
954 P.2d 290 (Court of Appeals of Washington, 1998)
Matter of Firestorm 1991
916 P.2d 411 (Washington Supreme Court, 1996)
Moore v. Wentz
525 P.2d 290 (Court of Appeals of Washington, 1974)
In re Firestorm 1991
129 Wash. 2d 130 (Washington Supreme Court, 1996)
State v. Rodriguez
550 P.2d 23 (Court of Appeals of Washington, 1976)
Holland v. City of Tacoma
954 P.2d 290 (Court of Appeals of Washington, 1998)
Brower v. Pierce County
984 P.2d 1036 (Court of Appeals of Washington, 1999)

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