Spectrum Capital North Bergen, LLC v. Crown Bank

CourtNew Jersey Superior Court Appellate Division
DecidedFebruary 27, 2025
DocketA-3581-22
StatusUnpublished

This text of Spectrum Capital North Bergen, LLC v. Crown Bank (Spectrum Capital North Bergen, LLC v. Crown Bank) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Spectrum Capital North Bergen, LLC v. Crown Bank, (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3581-22

SPECTRUM CAPITAL NORTH BERGEN, LLC,

Plaintiff-Appellant,

v.

CROWN BANK,

Defendant-Respondent. _________________________

Submitted November 7, 2024 – Decided February 27, 2025

Before Judges Rose and Puglisi.

On appeal from the Superior Court of New Jersey, Law Division, Hudson County, Docket No. L-1445-21.

Ferrara Law Group, PC, attorneys for appellant (Ralph P. Ferrara and Noah A. Schwartz, of counsel and on the briefs).

Hill Wallack LLP, attorneys for respondent (Mark A. Roney, of counsel and on the brief).

PER CURIAM Plaintiff Spectrum Capital North Bergen, LLC appeals from two June 13,

2023 Law Division orders that denied plaintiff's cross-motion for partial

summary judgment, granted defendant Crown Bank's motion for summary

judgment, and dismissed the amended complaint with prejudice. We affirm.

In February 2020, defendant issued a letter of interest (LOI) to provide

financing for plaintiff's commercial hotel property. Among other terms,

defendant agreed to lend up to $16 million, with up to $5 million financed by a

Small Business Administration (SBA) 504 loan through a Certified

Development Company (CDC).1 The LOI did not require plaintiff to obtain

approval of the SBA loan prior to closing on the loan with defendant.

Pursuant to the LOI, plaintiff paid defendant a $35,000 deposit to be

applied to the commitment fee, of which $30,000 would be refunded if defendant

did not issue a commitment letter. The entire deposit became non-refundable

upon defendant's approval of the loan request.

1 A 504 loan "provides long-term, fixed rate financing for major fixed assets that promote business growth and job creation." 504 Loans, Small Bus. Admin., https://www.sba.gov/funding-programs/loans/504-loans#what-is-the-504-loan- program- (last updated June 14, 2024). The "loans are available through [CDCs], SBA's community-based nonprofit partners who promote economic development within their communities." Ibid. A-3581-22 2 In March 2020, defendant approved the request for the proposed loan and

issued a commitment letter. The commitment letter reiterated certain terms and

conditions, including a condition precedent that defendant would close both

loans without CDC approval, "provided that a complete application has been

submitted to the CDC 504 [l]ender and reviewed by the bank." The commitment

letter expired on May 11, 2020 if the proposed loan was not closed on or before

that date.

The commitment letter further stated, "It is agreed that the commitment

fee and all fees to be paid have been earned upon issuance of this commitment

and are not refundable." Plaintiff accepted the terms and paid the outstanding

$210,000 commitment fee and $6,150 in other fees.

Shortly thereafter, defendant ordered an appraisal and feasibility study,

which was its responsibility under the LOI. Although the appraisal was

completed in June 2020, the feasibility study was not completed at that time

because of the COVID-19 pandemic.

In September 2020, the hotel opened for business under a temporary

certificate of occupancy. The following month, defendant received the appraisal

and delayed feasibility study and, because the May 11 closing deadline passed,

approved a ninety-day extension of the commitment letter, with additional

A-3581-22 3 conditions (the extension letter). The extension letter added the following

condition in large, bold font:

Approved with the following condition:

• Prior to closing [plaintiff] must obtain SBA approval for the 504 loan.

Plaintiff failed to obtain approval of the SBA loan by the extended

deadline and therefore the parties did not close on the proposed loan.

After the extended deadline passed, and plaintiff's initial complaint was

filed, defendant issued another modification to the commitment letter, proposing

to extend the closing date to June 16, 2021. Although defendant agreed to

certain modifications of the terms requested by plaintiff, plaintiff did not

execute the modified commitment letter and the loan did not close. Defendant

did not return the commitment fee or appraisal fee.

Plaintiff's amended complaint, filed June 17, 2021, asserted breach of

contract (count one), breach of the implied duty of good faith and fair dealing

(count two), unjust enrichment (count three), equitable estoppel (count four),

promissory estoppel (count five), and common law fraud (count seven)2 and

fraud under the Consumer Fraud Act (CFA), N.J.S.A. 56:8-1 to -229 (count

2 The amended complaint did not contain a count six. A-3581-22 4 eight). The complaint sought compensatory and consequential damages, interest

and attorneys' fees. Defendant answered the complaint and asserted affirmative

defenses. Upon the conclusion of discovery, defendant moved for summary

judgment and plaintiff cross-moved for summary judgment on counts one and

two.

After considering oral argument, Judge Kimberly Espinales-Maloney

issued a thirteen-page opinion and accompanying orders denying plaintiff's

cross-motion, granting defendant's motion, and dismissing the amended

complaint with prejudice.

On appeal, plaintiff advances the following arguments in support of its

claim the judge erred in granting summary judgment to defendant: 1) plaintiff

was not required to obtain the SBA loan as a condition precedent to closing; 2)

the loan commitment was an illusory contract and unenforceable; 3) plaintiff

was entitled to summary judgment on its claim of breach of the duty of good

faith and fair dealing; and 4) plaintiff's CFA claim should have been permitted

to reach a jury.

We review de novo a trial court's ruling on a motion for summary

judgment, applying the same standard used by the trial court. Samolyk v.

Berthe, 251 N.J. 73, 78 (2022) (citing Woytas v. Greenwood Tree Experts, Inc.,

A-3581-22 5 237 N.J. 501, 511 (2019)). We must decide whether "there is [a] genuine issue

as to any material fact" when the evidence is "viewed in the light most favorable

to the non-moving party." Davis v. Brickman Landscaping, Ltd., 219 N.J. 395,

405-06 (2014) (first quoting R. 4:46-2(c); and then quoting Brill v. Guardian

Life Ins. Co. of Am., 142 N.J. 520, 540 (1995)). "To decide whether a genuine

issue of material fact exists, the trial court must 'draw[ ] all legitimate inferences

from the facts in favor of the non-moving party.'" Friedman v. Martinez, 242

N.J. 449, 472 (2020) (alteration in original) (quoting Globe Motor Co. v.

Igdalev, 225 N.J. 469, 480 (2016)).

"The court's function is not 'to weigh the evidence and determine the truth

of the matter but to determine whether there is a genuine issue for trial.'" Rios

v. Meda Pharm., Inc., 247 N.J. 1, 13 (2021) (quoting Brill, 142 N.J. at 540). "If

there is no genuine issue of material fact, the court must then 'decide whether

the trial court correctly interpreted the law.'" DepoLink Ct. Reporting & Litig.

Support Servs. v. Rochman, 430 N.J. Super. 325, 333 (App.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Massachi v. AHL Services, Inc.
935 A.2d 769 (New Jersey Superior Court App Division, 2007)
Bosland v. Warnock Dodge, Inc.
964 A.2d 741 (Supreme Court of New Jersey, 2009)
Sons of Thunder, Inc. v. Borden, Inc.
690 A.2d 575 (Supreme Court of New Jersey, 1997)
Cox v. Sears Roebuck & Co.
647 A.2d 454 (Supreme Court of New Jersey, 1994)
Manalapan Realty v. Township Committee of the Township of Manalapan
658 A.2d 1230 (Supreme Court of New Jersey, 1995)
Wilson v. Amerada Hess Corp.
773 A.2d 1121 (Supreme Court of New Jersey, 2001)
Brill v. Guardian Life Insurance Co. of America
666 A.2d 146 (Supreme Court of New Jersey, 1995)
Wayne Davis v. Brickman Landscaping (071310)
98 A.3d 1173 (Supreme Court of New Jersey, 2014)
Globe Motor Company v. Ilya Igdalev(074996)
139 A.3d 57 (Supreme Court of New Jersey, 2016)
Tahisha Roach v. Bm Motoring, Llc(077125)
155 A.3d 985 (Supreme Court of New Jersey, 2017)
DepoLink Court Reporting & Litigation Support Services v. Rochman
64 A.3d 579 (New Jersey Superior Court App Division, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Spectrum Capital North Bergen, LLC v. Crown Bank, Counsel Stack Legal Research, https://law.counselstack.com/opinion/spectrum-capital-north-bergen-llc-v-crown-bank-njsuperctappdiv-2025.