Tiffanie Soetaert v. Novani Flips, LLC, Platinum Realty of Missouri, LLC

CourtMissouri Court of Appeals
DecidedAugust 3, 2021
DocketWD82933, WD82964
StatusPublished

This text of Tiffanie Soetaert v. Novani Flips, LLC, Platinum Realty of Missouri, LLC (Tiffanie Soetaert v. Novani Flips, LLC, Platinum Realty of Missouri, LLC) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tiffanie Soetaert v. Novani Flips, LLC, Platinum Realty of Missouri, LLC, (Mo. Ct. App. 2021).

Opinion

In the Missouri Court of Appeals Western District

 TIFFANIE SOETAERT,   Appellant-Respondent,  WD82933 Consolidated with v.  WD82964  NOVANI FLIPS, LLC,  OPINION FILED:  Respondent,  AUGUST 3, 2021  PLATINUM REALTY OF MISSOURI,  LLC,   Respondent-Appellant. 

Appeal from the Circuit Court of Jackson County, Missouri The Honorable Kevin D. Harrell, Judge

Before Division One: Alok Ahuja, Presiding Judge, Lisa White Hardwick, Judge, and Anthony Rex Gabbert, Judge

Tiffanie Soetaert and Platinum Realty of Missouri, LLC (“Platinum”) appeal and cross-

appeal the judgment of the Jackson County Circuit Court awarding Soetaert compensatory

damages, punitive damages, and attorneys’ fees in Soetaert’s suit for violation of the Missouri

Merchandising Practices Act (“MMPA) against Platinum, Novani Flips, LLC (“Novani”), and

MoreKC1, LLC (“MoreKC1”). In three points on appeal, Platinum claims the trial court erred in

finding it was liable under the MMPA, in instructing the jury, and in awarding punitive damages.

In one point on appeal, Soetaert claims the trial court erred in determining the amount of attorneys’

fees awarded. The judgment is affirmed in part and reversed and remanded in part. Facts

Nancy Mechlin is a licensed realtor with Platinum. She previously owned Missouri Real

Estate Exchange with Dan Reedy when they were married. It was a business that bought and sold

real estate. Missouri Real Estate Exchange later became MoreKC1 after Mechlin and Reedy

divorced, and she was no longer directly involved in that business.

While working with Reedy, Mechlin represented Matthew and Christa Phillipchuck (“the

Phillipchucks”) several times. They did not live in the United States. The Phillipchucks were

considered joint clients of Mechlin and MoreKC1 since MoreKC1 sold properties to them as

rentals and flips1 while Mechlin provided listings and managed rentals for them. Mechlin worked

with the Phillipchucks for several years before she listed the house at issue in this case. The

Phillipchucks were the owners of the LLC known as Novani in this case.

Even after their divorce, Reedy would send Mechlin potential investment opportunities and

ask her opinion about those investments. While Mechlin didn’t recall what information she

received as part of the transaction at issue in this case, she stated she would typically receive an

address, scope of work needed, and a document called “Best and Worst Case Analysis” from

Reedy. Sometimes she would receive pictures too. Mechlin would review the information Reedy

sent over and provide a generalized “best case” and “worst case” sales price based off of

comparable home sales in the neighborhood.

Reedy visited the house at issue in this case prior to its purchase. He observed cracks in

the foundation in the partially unfinished basement. He also observed evidence of water intrusion

in the basement. Reedy sent an email to Mechlin regarding the house, describing the property as

1 Flip refers to purchasing real estate, improving it, and then selling it in a relatively short period of time.

2 one that “NEEDS FULL REHAB” and inquired of Mechlin: “What’s your best case scenario retail

price . . . Can it get to $150k?” Mechlin responded something to the effect of “the numbers work.”

He informed the Phillipchucks of the house’s issues and presented it as an investment opportunity.

They purchased the house, and Reedy was in charge of making the necessary repairs and upgrades

before selling it. Reedy subcontracted out the work done on the house. Part of this work included

epoxy injections in the foundation, placing I-beams on the interior foundation wall, and creating a

yard swale. The basement was also finished with drywall.

Once work was completed, the house was listed for sale with Mechlin serving as the seller’s

agent for the Phillipchucks. The listing stated that the house was “completely renovated: and

“ready for a family to call it home.” Soetaert ultimately purchased the house in 2015.

During the purchase process, Soetaert received a sellers disclosure form. Mechlin filled

out the form for the Phillipchucks. Mechlin put a slash mark through twelve sections of the form.

She wrote that the sellers lived out of the country, had never visited the property, and had limited

knowledge. Mechlin slashed through the section asking about water intrusion and repairs that had

been made to the foundation. She attached a scope of work document to the disclosure. That

document referenced four piers being put in the foundation but did not address water intrusion or

the epoxy injections.

After purchasing the home, Soetaert began experiencing water intrusion in the finished

basement. She ultimately had the problem fixed at a cost of $13,950, which included pushing the

wall back 24 inches, installing five interior braces, and installing a sump pump and back up pump.

The cost of repairs did not include the expense involved with restoring the basement paneling,

sheetrock, and carpet.

3 Soetaert filed a petition against Novani, MoreKC1, and Platinum alleging Count I –

Violation of the Missouri Merchandising Practices Act, Count II – Fraudulent Misrepresentation,

and Count III – Civil Conspiracy. A jury trial was held beginning December 10, 2018. Soetaert

abandoned her Fraudulent Misrepresentation and Civil Conspiracy claims and submitted to the

jury only on the Violation of the Missouri Merchandising Practices Act claim.

The jury returned a verdict in the amount of $25,000 in compensatory damages against

each defendant, $75,000 in punitive damages against Novani, $75,000 in punitive damages against

MoreKC1, and $25,000 in punitive damages against Platinum. The trial court granted Platinum’s

motion for amended judgment and merged the compensatory damages into a single award for

$25,000. The trial court then entered a second amended judgment awarding Soetaert $11,623.47

in attorneys’ fees and costs.

Platinum’s appeal and Soetaert’s cross-appeal follow.

Platinum’s Point I

In its first point on appeal, Platinum claims the trial court erred in denying its motion for

judgment notwithstanding the verdict as to liability on Soetaert’s claim for violation of the MMPA.

It states that section 339.730 precludes liability for a real estate licensee acting as a seller’s agent

for failing to disclose or failing to discover adverse material facts regarding a property unless the

adverse material facts are actually known or should have been known by the licensee without an

independent inspection. Platinum further maintains that section 339.190 precludes liability for a

real estate licensee for any information in a seller’s disclosure unless the licensee is a signatory or

knew prior to closing that the statement was false or the licensee acted in reckless disregard as to

whether the statement was true or false. It concludes that there was no evidence Platinum knew

or should have known of the condition of the basement, Platinum did not sign the seller’s

4 disclosure, and Platinum did not know or act in reckless disregard as to whether statements

contained therein were true or false.

“The standard of review for failures to sustain motions for directed verdict and for JNOV

is essentially the same.” Fleshner v. Pepose Vision Inst., P.C., 304 S.W.3d 81, 95 (Mo. banc 2010).

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Tiffanie Soetaert v. Novani Flips, LLC, Platinum Realty of Missouri, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tiffanie-soetaert-v-novani-flips-llc-platinum-realty-of-missouri-llc-moctapp-2021.