William C. Robbins v. Maxwell-GMII, Inc.

CourtCourt of Appeals of Texas
DecidedMay 12, 2011
Docket01-10-00141-CV
StatusPublished

This text of William C. Robbins v. Maxwell-GMII, Inc. (William C. Robbins v. Maxwell-GMII, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
William C. Robbins v. Maxwell-GMII, Inc., (Tex. Ct. App. 2011).

Opinion

Opinion issued May 12, 2011

In The

Court of Appeals

For The

First District of Texas

————————————

NO. 01-10-00141-CV

———————————

William C. Robbins, Appellant

V.

Maxwell-GMII, Inc., Appellee

On Appeal from the 11th District Court

Harris County, Texas

Trial Court Case No. 2008-64346

MEMORANDUM OPINION

This is a dispute over who is entitled to the earnest money deposited by the potential buyer of an automobile dealership when the transaction failed to close.  The trial court granted summary judgment, concluding that the seller was entitled to retain the earnest money.  We affirm.

Background

On July 25, 2008, Plaintiff/Appellant William C. Robbins entered into an Asset Purchase Agreement (“APA”) to purchase a San Antonio automobile dealership, Freedom Chevrolet, from Defendant/Appellee Maxwell-GMII, Inc.  In accordance with the APA’s terms, Robbins deposited $250,000 in earnest money with an escrow agent.   

1.     The APA’s earnest money provisions

The APA provides for disbursement of the earnest money to either Robbins or Maxwell, depending on whether the contemplated transaction closed and, if it did not, depending on the reason.  Each scenario provides for disbursement to Maxwell, the seller, except:

If Purchaser elects not to close because of Seller’s default or the failure to satisfy any of the conditions in Sections 4.1.1, 4.1.5., or 4.1.8 below, then the Earnest Money Deposit shall be returned to Purchaser.

The parties agree that Maxwell was never in default, and that Section 4.1.1 is the only condition at issue here.  It provides:

4.1.    Conditions Precedent to Obligations of Purchaser.  The obligations of Purchaser to consummate the transactions contemplated by this Agreement at the Closing are subject to the satisfaction, or the written waiver by Purchaser, of each of the following conditions:

4.1.1. Unconditional approval by the Manufacturer of Purchaser for a new Sales and Service Agreement for Chevrolet on Chevrolet’s standard form.

Robbins received this unconditional approval from General Motors (“GM”) on October 9, 2008, seventy-six days after the APA was entered.  It is the effect of the timing of that approval upon which this dispute turns.

2.     Closing date

Section 5.1 of the APA provides that:

Unless otherwise agreed to in writing by the parties, closing of the transactions contemplated by this Agreement shall take place at the Dealership Location on the first Monday, following the satisfaction or waiver of the conditions contained in Section 4, above (“Closing Date”), or such other date as mutually agreed by Seller and Purchaser.  If the Closing has not occurred on or before the date that is sixty (60) days after the date of this Agreement (“Closing Date Deadline”), either party may terminate this Agreement by written notice to the other party, provided that rights and remedies of a party arising from or related to a breach of this Agreement shall survive the termination.

The parties entered a Letter Agreement, also on July 25, 2008, memorializing an additional agreement related to section 5.1 of the APA and the timing of the approvals serving as conditions precedent under the APA:

Section 5.1 of the [APA] states that either party may terminate the [APA] if Closing has not occurred by the Closing Date Deadline.  Section 4.1.1 of the [APA] states that it is a condition precedent to Purchaser’s obligation to consummate the transactions contemplated by the [APA] that Purchaser receive unconditional approval by [General Motors]. . . . If Closing has not occurred by the Closing Date Deadline and the only remaining conditions are Manufacturer approval as contemplated by Section 4.1.1 . . . Purchaser may extend the Closing Date Deadline two (2) times by written notice to Seller prior to the original or the extended, as the case may be, Closing Date Deadline for an additional thirty (30) days each.

On the Closing Date Deadline of September 23, 2008 (60 days following the date of execution of the APA), approval from GM had not been received.  At this point, Robbins did not, however, “terminate this Agreement by written notice” as permitted under 5.1, or “extend the Closing Date Deadline . . . by written notice to Seller prior to the . . . Closing Date Deadline” as permitted by the Letter Agreement.  Instead, he met with Mr. Callison, a representative of Maxwell’s, on September 25, 2008 and told Callison that he was only interested in moving forward under the APA if the dealership price was reduced.  According to Robbins, Callison suggested that Robbins not formally terminate the APA, and that Robbins continue seeking GM approval and propose a reduced purchase price after the approval was obtained.  After GM approval was received on October 9, 2008, Robbins offered a lower price that was rejected by Maxwell.  On October 16, 2008, Maxwell requested a closing under the APA, noting that all the conditions had been satisfied.  The following day, Robbins’s attorney sent written notice that Robbins “has terminated the [APA] . . . due to our client’s failure to obtain General Motor’s Corporation’s approval . . . by the Closing Date Deadline (as defined by the [APA]).” That letter also requested immediate return of the $250,000 earnest money deposit, plus interest.  Maxwell refused to return the earnest money.

3.    

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William C. Robbins v. Maxwell-GMII, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-c-robbins-v-maxwell-gmii-inc-texapp-2011.