Vaughn v. Virginia Real Estate Commission

7 Va. Cir. 301, 1986 Va. Cir. LEXIS 40
CourtWarren County Circuit Court
DecidedAugust 25, 1986
DocketCase No. (Chancery) 4352
StatusPublished

This text of 7 Va. Cir. 301 (Vaughn v. Virginia Real Estate Commission) is published on Counsel Stack Legal Research, covering Warren County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vaughn v. Virginia Real Estate Commission, 7 Va. Cir. 301, 1986 Va. Cir. LEXIS 40 (Va. Super. Ct. 1986).

Opinion

By JUDGE ROBERT K. WOLTZ

This is an appeal under the Administrative Process Act, Code §§ 9*6.14:1, et seq., by Donald W. Vaughn, a real estate broker, from a decision of the Virginia Real Estate Commission. The Commission found him in violation of certain of its regulations and imposed the sanction of a sixty-day suspension of his license as a broker and a fine of $500. The grounds for appeal are essentially that the decision of the Commission is unsupported by the evidence and results from the application of an error in law.

Factually the problem arises because of the existence of termites in a house listed by Vaughn in a multiple listing service but sold by another broker in 1978. The listing described the house as in good condition.

In 1972 Vaughn had sold the same house to a building contractor in "as is" condition because of termite infestation, inference being that a contractor would be able to repair the damage whereas an ordinary buyer would not want the property. After one or more sales in which Vaughn was not involved, in 1977 he was again broker in the sale of the house. This purchaser found extensive termite damage. As a result Vaughn arranged for the seller to grant the purchaser a $5,000 credit on the purchase money deed of trust, which credit was made a matter of [302]*302public record. Vaughn observed this purchaser personally making repairs due to the termite damage and was informed by the purchaser that he personally had given the house termite treatment, though the purchaser was a lay person in that respect.

Next, under the 1978 contract of sale the purchasers were entitled to a termite certificate. Because of weather and other conditions termite experts were unable to make sufficient inspection to supply the certificate. One inspector testified that in front of Vaughn’s office he had informed a sales employee of Vaughn that his partial inspection had disclosed termite damage and that with this information the employee forthwith had gone into Vaughn’s offices. The employee testified that he had no recollection of this occurrence.

Subsequently at closing at the financial institution’s office Vaughn and the purchasers, who were unrepresented by counsel, were present. In lieu of a termite certificate Vaughn suggested that $250 of the purchase price be placed in escrow for possible "termite treatment," to which the purchasers were agreeable. Within a short time of closing these purchasers became aware of problems, which on inspection by termite experts showed extensive termite infestation and damages. A suit by the purchasers was settled by means of Vaughn’s buying the house from them for the purchase price they had paid, plus their attorney fees and other expenses.

The report of the Hearing Officer of the Commission found Vaughn in violation of Regulation 8.2(2) of the Commission by making a misrepresentation as to the property sold. The conclusion also finds Vaughn in violation of 8.2(36) based on several factors, including "knowledge which is by law imputed to Vaughn because it was reported to his employed salesman, Brown, by the exterminator," and two violations of 8.2(8), the first violation referring to "knowing by imputation" the report of the exterminator and the second violation founded on "his conduct, aforementioned." In its Opinion and Order the Commission accepted, adopted and incorporated by reference "the Report and Recommendations [of the Hearing Officer] in toto.”

Judicial review of administrative actions poses some difficulties and delicacy. 2 Am. Jur. 2d, Administrative Law, §§ 552 and 553. Implicit in that review are the concepts of separation of powers and judicial restraint. See Aetna Insurance Co. v. Commonwealth, 160 [303]*303Va. 698 (1933). As a judicial doctrine now often given statutory form courts in general have restrained themselves from invading the just province of the executive and legislative branches, and also more recently with the rise of administrative agencies their area of responsibility, whether these agencies, as they sometimes are, looked upon as a fourth branch of government or part of one of the two political branches or some sort of hybrid. Not only by case law does this doctrine find expression, but now in Virginia is embodied in the Administrative Process Act. It says in pertinent part in § 9-6.14:17:

The burden shall be upon the party complaining of agency action to designate and demonstrate an error of law subject to review by the court. Such issues of law include. . . (4) the substantiality of the evidential support for findings of fact. . . When the decision on review is so to be made on such agency record, the duty, of the court with respect to issues of fact is limited to ascertaining whether there was substantial evidence in the agency record upon which the agency as the trier of facts could reasonably find them to be as it did. . . . [T]he court shall take account of the presumption of official regularity, the experience and specialized competence of the agency, and the purposes of the basic law under which the agency has acted.

This statute limits the scope of judicial review to whether there is "substantial evidence in the agency record" supporting the agency's decision. State Board of Health v. Godfrey, 223 Va. 423 (1982). This standard is explicated in Virginia Real Estate Commission v. Bias, 226 Va. 264, 269 (1983):

The "substantial evidence" standard, adopted by the General Assembly, is designed to give great stability and finality to the fact-findings of an administrative agency. The phrase "substantial evidence" refers to "such relevant evidence as a reasonable mind might accept as adequate to support a conclusion." Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229 (1938). (Emphasis [304]*304added.) Under this standard, applicable here, the court may reject the agency’s finding of fact "only if, considering the record as a whole, a reasonable mind would necessarily come to a different conclusion." B. Mezines, Administrative Law, § 51.01 (1981). (Emphasis in original.)

In accordance with these principles of showing due deference to the finder of fact, the presumption of official regularity, the agency’s expertise and the purposes of the law under which the agency acted the Court affirms the first conclusion of the Commission as to Vaughn’s making a misrepresentation. There is a difficulty, however, with the remaining three conclusions of the Commission. All three of them are based at least in part on the theory of imputation to Vaughn of his employee Brown's knowledge of existing termite damage. As asserted by Vaughn, this imputation of knowledge to him is an error of law.

It is an elemental principle of law with some specific exceptions that at least in purely civil matters knowledge had by an agent or employee is by imputation known by the principal or employer. (As the salesman Brown was not actually engaged in the real estate transaction at hand he was in this instance not Vaughn's agent but rather his employee or servant, but this distinction is not of material importance here.) This is parallel to if not a part of the doctrine of respondeat superior,

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Related

First Virginia Bank, National Ass'n v. Commonwealth
193 S.E.2d 4 (Supreme Court of Virginia, 1972)
Virginia Real Estate Commission v. Bias
308 S.E.2d 123 (Supreme Court of Virginia, 1983)
State Board of Health v. Godfrey
290 S.E.2d 875 (Supreme Court of Virginia, 1982)
Greene v. Real Estate Commission
218 A.2d 508 (District of Columbia Court of Appeals, 1966)
McKey & Poague, Inc. v. Stackler
379 N.E.2d 1198 (Appellate Court of Illinois, 1978)
Aetna Insurance v. Commonwealth
169 S.E. 859 (Supreme Court of Virginia, 1933)

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Bluebook (online)
7 Va. Cir. 301, 1986 Va. Cir. LEXIS 40, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vaughn-v-virginia-real-estate-commission-vaccwarren-1986.