Winecup Gamble, Inc. v. Gordon Ranch LP

CourtDistrict Court, D. Nevada
DecidedMarch 1, 2023
Docket3:17-cv-00163
StatusUnknown

This text of Winecup Gamble, Inc. v. Gordon Ranch LP (Winecup Gamble, Inc. v. Gordon Ranch LP) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Winecup Gamble, Inc. v. Gordon Ranch LP, (D. Nev. 2023).

Opinion

2 UNITED STATES DISTRICT COURT 3 DISTRICT OF NEVADA 4 WINECUP GAMBLE, INC., Case No. 3:17-cv-00163-ART-CSD 5 Plaintiff, ORDER 6 v.

7 GORDON RANCH, LP,

8 Defendant.

9 10 The parties in this consolidated action both lay claim to $5 million in 11 earnest money deposited into escrow by defendant Gordon Ranch, LP (“Gordon 12 Ranch”) in 2016 when Gordon Ranch sought to purchase the Winecup Gamble 13 Ranch from plaintiff Winecup Gamble, Inc. (“Winecup”). Prior to the closing date, 14 severe flooding significantly damaged the property which Winecup elected not to 15 restore pursuant to the risk-of-loss provisions in the purchase agreement, and 16 Gordon Ranch in turn elected not to continue with the sale. Winecup now moves 17 for summary judgment. (ECF No. 193.) The parties dispute whether an 18 amendment to the purchase agreement which ostensibly made the earnest money 19 nonrefundable under all circumstances other than a default by Winecup altered 20 the risk-of-loss provisions in the purchase agreement; whether, if so, the receipt 21 of the earnest money by Winecup would be an unenforceable punitive windfall; 22 and whether Winecup defaulted by not restoring the property. Gordon Ranch also 23 moves for judgment on the pleadings on the basis that a standalone cause of 24 action for declaratory relief is unavailable (ECF No. 220) and for sanctions against 25 Winecup for allegedly withholding and spoliating evidence (ECF No. 197.) For the 26 reasons set forth in this order, the Court: (1) denies Gordon Ranch’s motion for 27 judgment on the pleadings; (2) denies Gordon Ranch’s motion for sanctions; and 28 (3) denies Winecup’s motion for summary judgment. 1 I. BACKGROUND 2 This case has a lengthy litigation history. Gordon Ranch removed this case 3 to this Court on March 16, 2017 (ECF No. 1), and the case was consolidated with 4 Gordon Ranch LP v. Winecup Gamble, Inc., 3:17-cv-00157-RCJ-WGC, on May 5 23, 2017 (ECF No. 26). The Court summarizes the basic allegations made by the 6 parties and the procedural history of this case, including two orders by the Ninth 7 Circuit Court of Appeals (“Ninth Circuit”), the scope of which are relevant to the 8 instant motions. 9 A. GENERAL ALLEGATIONS 10 Winecup and Gordon Ranch entered into a Purchase and Sale Agreement 11 with an effective date of October 18, 2016 (the “Purchase Agreement”) for sale of 12 approximately 247,500 acres, together with other real and personal property 13 rights, interests, and cattle, in Elko County, Nevada. (ECF No. 1-1 (“Complaint”) 14 at ¶¶ 6–7; ECF No. 194-1 (“Purchase Agreement”).) The Purchase Agreement 15 required $1 million of earnest money to be deposited by Gordon Ranch into 16 escrow. (Complaint at ¶ 8.) This money was refundable to Gordon Ranch if 17 Gordon Ranch decided to terminate the Purchase Agreement prior to issuing a 18 Notice to Proceed. (Id. at ¶ 9.) The closing was to occur between January 2 and 19 January 12, 2017. (Id. at ¶ 11.) 20 Section 14 of the Purchase Agreement set forth the risk-of-loss provisions 21 for the Purchase Agreement. (Id. at ¶ 12.) These provisions provided that “if, prior 22 to Close of Escrow, the Property or any portion thereof is materially damaged as 23 the result of fire or other casualty, and Seller [Winecup] elects (which Seller may 24 elect to do in its sole discretion) not to entirely restore the Property, […] Buyer 25 shall have the option to: (a) Accept title to the Property without any abatement of 26 the Purchase Price[,] in which event […] all of Seller’s insurance proceeds […] 27 shall be paid over to Buyer; or (b) Terminate this Agreement, in which event all 28 Earnest Money and interest accrued thereon shall be returned to Buyer[.]” (Id. at 1 ¶¶ 13–14; Purchase Agreement at ¶ 14.) The Purchase Agreement also contained 2 a provision stating that the earnest money would be refundable “[i]n the event of 3 a failure by Seller to meet a material obligation under this Agreement[.]” 4 (Purchase Agreement at ¶ 8(a).) 5 In December of 2016, Gordon Ranch informed Winecup that it desired an 6 extension of time for closing. (Complaint at ¶ 15.) The parties executed an 7 Amendment to the Purchase Agreement dated December 21, 2016 (the 8 “Amendment”) which extended the time for closing to “on or before April 15, 9 2017[.]” (Id. at ¶ 17; ECF No. 194-2 (“Amendment”).) The Amendment required 10 an increase of the earnest money from $1 million to $5 million and modified 11 certain conditions relating to the earnest money. Notably, the Amendment stated 12 that “notwithstanding anything to the contrary in the [Purchase] Agreement, the 13 Earnest Money, as increased by the Additional Earnest Money, shall be 14 nonrefundable under all circumstances other than a default by Seller.” 15 (Complaint at § 20; Amendment at ¶ 2.) The Amendment also stated that “[i]n the 16 event of any conflict between the terms and provisions of the [Purchase] 17 Agreement and this First Amendment, the terms and provisions of this First 18 Amendment shall control.” (Amendment at ¶ 8.) 19 In February of 2017, which was after the execution of the Amendment and 20 before the new closing date, severe flooding damaged the property. (Complaint at 21 ¶ 23.) On March 2, 2017, counsel for Gordon Ranch sent Winecup a letter which 22 claimed that the Purchase Agreement required Winecup to deliver the property 23 in the condition it was in when Gordon Ranch entered the Purchase Agreement 24 and that failure to do so would be a breach of the Purchase Agreement. (Id. at ¶ 25 24.) This letter stated that if Winecup did not cure its putative breach within five 26 business days, Gordon Ranch would terminate the Purchase Agreement. (Id. at ¶ 27 27.) Gordon Ranch stated that they would be entitled to a refund of the earnest 28 money under both Section 8(a) of the Purchase Agreement as well as NRS 1 113.040. (ECF No. 194-11 at 2.) Winecup takes the position that Winecup is not 2 in breach for electing not to restore the property since the Purchase Agreement 3 expressly places that decision within the sole discretion of Winecup and that 4 Gordon Ranch, although permitted to elect not to continue with the sale, is not 5 entitled to a refund of the earnest money pursuant to the provision of the 6 Amendment stating that the earnest money is nonrefundable in all circumstances 7 other than default by Winecup. (ECF No. 193 at 16–25.) 8 B. PROCEDURAL HISTORY 9 Both parties filed actions seeking a declaration that they, respectively, are 10 entitled to the earnest money. Winecup filed its action in the Fourth Judicial 11 District Court of the State of Nevada, which asserted a claim for declaratory 12 judgment under Nevada’s enactment of the Uniform Declaratory Judgments Act. 13 (Complaint.) Gordon Ranch filed an action in this Court seeking declaratory 14 judgment.1 (ECF No. 1 in 3:17-cv-00157-RCJ-WGC.) After Gordon Ranch 15 removed Winecup’s action to this Court, the Court consolidated the two actions 16 (ECF No. 26) and the parties agreed to a streamlined briefing schedule without 17 engaging in discovery (ECF No. 24). Winecup then brought a motion for summary 18 judgment which argued that the Purchase Agreement as modified by the 19 Amendment establishes as a matter of law that Winecup is entitled to the earnest 20 money since the Amendment provides that the earnest money is nonrefundable 21 under all circumstances, including flooding, other than default by Winecup, and 22 Winecup did not default. (ECF No.

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Winecup Gamble, Inc. v. Gordon Ranch LP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/winecup-gamble-inc-v-gordon-ranch-lp-nvd-2023.