Weldon D. Bloom and Karen Wickwire, as Co-Trustees of the Weldon D. Bloom Revocable Trust v. Michael Oniayekan and Ijeoma Asota

CourtCourt of Appeals of Iowa
DecidedMarch 7, 2018
Docket16-1444
StatusPublished

This text of Weldon D. Bloom and Karen Wickwire, as Co-Trustees of the Weldon D. Bloom Revocable Trust v. Michael Oniayekan and Ijeoma Asota (Weldon D. Bloom and Karen Wickwire, as Co-Trustees of the Weldon D. Bloom Revocable Trust v. Michael Oniayekan and Ijeoma Asota) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Weldon D. Bloom and Karen Wickwire, as Co-Trustees of the Weldon D. Bloom Revocable Trust v. Michael Oniayekan and Ijeoma Asota, (iowactapp 2018).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 16-1444 Filed March 7, 2018

WELDON D. BLOOM and KAREN WICKWIRE, as Co-Trustees of the WELDON D. BLOOM REVOCABLE TRUST, Plaintiffs-Appellees/Cross-Appellants,

vs.

MICHAEL ONIAYEKAN and IJEOMA ASOTA, Defendants-Appellants/Cross-Appellees. ________________________________________________________________

Appeal from the Iowa District Court for Scott County, Stuart P. Werling,

Judge.

Oniayekan appeals the district court’s ruling in favor of Bloom in this breach

of contract action. Bloom cross-appeals. AFFIRMED ON BOTH APPEALS AND

REMANDED.

William R. Stengel of Stengel, Bailey & Robertson, Rock Island, Illinois, for

appellants.

Katherine Varlas Teel of Pepping, Balk & Kincaid, Ltd., Silvis, Illinois, for

appellees.

Considered by Vaitheswaran, P.J., and Doyle and Bower, JJ. 2

VAITHESWARAN, Presiding Judge.

Buyers of a home terminated the real estate purchase contract. The sellers

sued and obtained judgment against them. On appeal, the buyers contend a

mutual mistake of fact precluded formation of the contract. The sellers cross-

appeal for additional damages and attorney fees.

I. Background Facts and Proceedings

Plaintiffs Weldon Bloom and Karen Wickwire owned a home in Davenport,

Iowa. Defendants Ijeoma Asota and Michael Oniayekan made an offer to

purchase the property, which was accepted. A purchase agreement was executed

in late August 2014.

At the same time, Bloom completed a seller’s disclosure statement. He left

blank the question, “Any easements or encroachments onto or from neighboring

properties?” He later amended the disclosure statement to answer “No” to the

question.

In late September 2014, the City Public Works Department’s real estate

manager sent Bloom a certified letter requesting a meeting to discuss a permanent

recreational trail easement and a temporary construction easement. Bloom picked

up the letter on October 4, 2014. Shortly thereafter, he forwarded it to the listing

agent who, in turn, sent it to the buyers’ agent.

On October 15, 2014, the buyers’ agent informed the listing agent that the

buyers were terminating the contract. The reason given on the termination

document was: “Due to the city of Davenport taking part of the land. The

purchasers intended to use the backyard for their small child to play safely.” The 3

City never took title to the land and did not record the easements until

approximately one year after the buyers terminated the contract.

The buyers failed to appear on the scheduled closing date in November

2014. Several months later, the sellers sold the property to another purchaser.

Bloom and Wickwire sued Oniayekan and Asota for breach of contract.

Following trial, the district court entered judgment in favor of Bloom and Wickwire.

The buyers appealed, and the sellers cross-appealed.

II. Buyers’ Appeal – Mutual Mistake

Oniayekan and Asota contend they “did not complete the purchase

[agreement] as they did not know at the time of signing the purchase agreement”

that the property was “subject to temporary and permanent easements.” They

concede Bloom and Wickwire also were unaware of the easements. In their view,

“This mutual lack of knowledge of a material issue leads to avoidance of the

contract based on mutual mistake.”

A. Error Preservation

Bloom and Wickwire preliminarily contend the buyers failed to preserve

error because they did not raise the defense of mutual mistake in their answer or

amended answer. “Failure to plead an affirmative defense normally results in

waiver of the defense, unless the issue is tried with the consent of the parties.”

Dutcher v. Randall Foods, 546 N.W.2d 889, 893 (Iowa 1996). The buyers did not

plead the defense, but the mutual mistake issue was tried by consent. Specifically,

both sides raised the issue at trial and both sides presented written argument

addressing the issue. The sellers concede “the district court ruled on [the] 4

affirmative defense, despite the fact that it was not properly pled.” The issue was

preserved for review.

B. Scope of Review

The buyers assert our review of this “specific performance contract breach”

is de novo. We disagree.

The sellers did not request specific performance. They styled their action a

“petition at law,” pled an at-law breach-of-contract cause of action, and sought a

money judgment against the buyers. They made a jury demand.1 A trial

scheduling and discovery plan document listed the action as a law action. At trial,

the court ruled on objections. All these circumstances are hallmarks of a law action

rather than an equity action. See Westco Agronomy Co., LLC v. Wollesen, ___

N.W.2d ___, ___, 2017 WL 6545853, at *11 (Iowa 2017) (“[L]aw issues are for the

jury and equity issues are for the court.”); Harrington v. Univ. of N. Iowa, 726

N.W.2d 363, 365 (Iowa 2007) (noting case was filed as a law action and tried at

law and the court ruled on the objections, making appellate review for correction

of errors at law); Bacon ex rel. Bacon v. Bacon, 567 N.W.2d 414, 417 (Iowa 1997)

(same); Harding v. Willie, 458 N.W.2d 612, 613 (Iowa Ct. App. 1990) (“The

essential character of a cause of action and the relief it seeks, as shown by the

complaint, determine whether an action is at law or equity.”).

We recognize “[a] mistake of fact is one of the fundamental grounds of

equitable relief.” Harding, 458 N.W.2d at 614; see also Gouge v. McNamara, 586

N.W.2d 710, 713 (Iowa Ct. App. 1998) (“[C]ourts of equity have jurisdiction to

1 They later withdrew the demand, without comment. 5

relieve parties against the consequences of mutual mistake of fact, and to grant

reformation in case of such a mistake.”). But a request for this equitable remedy

does not alter our conclusion that the action was at law, where the case was filed

and tried at law. Harrington, 726 N.W.2d at 365. Our review is for errors of law.

C. Mistake of Fact

“A mistake is a belief that is not in accord with the facts.” Nichols v. City of

Evansdale, 687 N.W.2d 562, 570 (Iowa 2004) (quoting Restatement (Second) of

Contracts § 151 (1981)). “Mistakes in the formation of contracts include mistakes

in an underlying assumption concerning matters relevant to the decision to enter

into a contract.” Id. (quoting State ex rel. Palmer v. Unisys Corp., 637 N.W.2d 142,

151 (Iowa 2001)).

At the time of the contract, none of the parties could have made a mistake

about the easements because the easements were not in existence. The parties

entered into the real estate purchase contract on August 30, 2014. Notice about

the easements was sent to Bloom on September 30, 2014. According to the City’s

real estate manager, the easements had not been finalized as of that date or even

at the time of the scheduled closing six weeks later.

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State v. Hager
630 N.W.2d 828 (Supreme Court of Iowa, 2001)
State, Department of Human Services Ex Rel. Palmer v. Unisys Corp.
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NevadaCare, Inc. v. Department of Human Services
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Harrington v. University of Northern Iowa
726 N.W.2d 363 (Supreme Court of Iowa, 2007)
Nichols v. City of Evansdale
687 N.W.2d 562 (Supreme Court of Iowa, 2004)
MacAl v. Stinson
468 N.W.2d 34 (Supreme Court of Iowa, 1991)
Dutcher v. Randall Foods
546 N.W.2d 889 (Supreme Court of Iowa, 1996)
HARDING MD v. Willie
458 N.W.2d 612 (Court of Appeals of Iowa, 1990)
Beckman v. Kitchen
599 N.W.2d 699 (Supreme Court of Iowa, 1999)
Gouge v. McNamara
586 N.W.2d 710 (Court of Appeals of Iowa, 1998)
Landals v. George A. Rolfes Co.
454 N.W.2d 891 (Supreme Court of Iowa, 1990)

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