Patterson v. . Meyerhofer

The written contract covered only four parcels. Although Patterson alleged a prior oral agreement under which he would buy all five parcels and retain the fifth, the trial court made no finding that such an agreement existed. In any event, the Court saw no basis for enforcing a merely oral agreement concerning that additional parcel.

A vendee can sometimes be prevented from acquiring and asserting a superior title against a vendor. But those cases involved purchasers who had completed their purchase, entered possession under the vendor, and later sought to disavow the vendor's title. In that setting, the vendee occupies a position analogous to a tenant and may not deny the vendor's title.

Meyerhofer never entered into possession under Patterson or accepted his title. Instead, before the foreclosure sale, she expressly repudiated the contract and announced that she would bid on her own behalf. Her purchase was therefore adverse to Patterson, not an acquisition made for him, and it did not create a trust relationship.

Every contract carries an implied undertaking that neither party will intentionally hinder or prevent the other from performing. A party who causes the nonperformance of a contractual condition cannot rely on that nonperformance to escape liability.

Meyerhofer knew when she signed the contract that Patterson needed to buy the four parcels at the foreclosure sale before he could convey them to her. Her promise to purchase from him therefore necessarily included a promise not to prevent him from acquiring the very title he needed to perform.

Patterson attended the sale prepared to purchase, and Meyerhofer consistently outbid him. The Court presumed that, absent her interference, he could have acquired the parcels for the prices she paid. Because she purchased them for $620 less than her contract price, $620 was the profit Patterson lost through her breach.

Patterson expressly demanded $620 in damages in his complaint. That amount was not dependent on the requested trust remedy; it represented the direct loss resulting from Meyerhofer's interference with his ability to acquire and resell the four parcels under the written contract.

The Court held that a plaintiff should not be turned out of court merely because he sought excessive or unavailable equitable relief along with a valid damages claim. A new trial was appropriate so that the damages claim could be resolved.