Judge 'Compelled' to Rule for South Florida Developers in Attorney Fees Dispute
"Although the buyers' misconduct was reprehensible ... this court lacks a mechanism to punish the miscreant defendants," Fourth District Court of Appeal Judge Alan Forst wrote.
January 25, 2018 at 03:44 PM
5 minute read
Fourth District Court of Appeal Judge Alan Forst seemed to have his hands tied in a case involving an attorney who took a clandestine $100,000 payment from South Florida developers to act against his client in a real estate deal.
Forst sat on the appellate panel adjudicating whether to award attorney fees to widows who claim lawyers and developers defrauded them on a $6.2 million sale of a Boca Raton cemetery following their husbands' deaths.
After trial in Palm Beach Circuit Court, “the jury entered a verdict against the buyers on all counts,” according to the appellate ruling. But jurors also found the women sustained no damages from the transaction. They awarded no compensatory damages, but included $2 million in attorney fees and costs for a $2.11 million award against a corporate defendant and another $100,000 against a principal, Edward Falcone.
That lack of compensatory damages became a central issue in the case, because the defense argued it showed the jury believed the widows suffered no losses as a result of the fraud.
The appeal turned on whether an award of attorney fees as a punishment for the developers went beyond the goal of damages in tort cases, which seek to “restore the injured party to the position it would have been in had the wrong not been committed,” according to the appellate court.
The Fourth DCA ruled in favor of the defendants Wednesday, finding the award improper in a case where the plaintiff did not seek to rescind the contract, yet sought attorney fees to cover the transaction.
“Once the sellers picked affirmance over rescission, their damages were limited to the difference between the sale price and the fair market value at the time of the sale,” Judge Spencer Levine wrote, with Judge Jefferey Kuntz concurring.
But Forst seemed especially torn.
“Although the buyers' misconduct was reprehensible, in the absence of compensatory damages, this court lacks a mechanism to punish the miscreant defendants,” he wrote in a special concurrence. “Accordingly, I am compelled to concur with the majority opinion.”
The case involved developers—brothers Arthur and Edward Falcone—and their company DFG Group LLC, who were the buyers in the deal with the widows.
The sellers hired Boca Raton-based Sachs Sax Caplan and its attorneys Michael D. Masanoff and Michael D. Karschto to handle the transaction. But their court pleadings show the women later learnt the buyers paid Masanoff $100,000, which he never disclosed to his clients.
The two sides disagree on the nature of the payment. The plaintiffs called it a kickback. Their claims eventually led to a settlement with the attorneys, and revocation of Masanoff's law license in 2014, with leave to seek readmission to the Florida Bar within five years.
Defense attorneys characterized it as a finder's fees, which Masanoff demanded from the buyers.
'Far From Over'
The Falcones purchased Heritage Manor of Memorial Park Inc. after the project's previous developers died, and the development company could not meet construction costs. Their court pleadings claim the successor developers assumed a high risk, purchasing a business and real estate parcel embroiled in litigation by clients who paid thousands for burial sites that had not been built. At trial, they called on appraisers who valued the real estate parcel at about $4 million, and said the business had zero value.
“From day one, my clients argued through the courts and have always maintained that we paid in excess of the fair market value when we purchased it,” defense attorney William J. Cornwell, of Weiss Handler & Cornwell in Boca Raton, said. “Regardless of whether a lawyer violated his ethical obligations to the his client, they were never damaged.”
The litigation has been hard-fought for about 12 years, with more than 2,450 docket entries since 2005.
Lead counsel for the plaintiffs, Michael J. Avenatti of Eagan Avenatti in Newport Beach, California, suggested his clients might seek rehearing or review before Florida's Supreme Court after this week's ruling.
“The opinion does not exonerate the Falcones for their proven fraudulent conduct,” Avenatti said. “In fact, the judges went out of their way to make it clear their conduct aimed at the two widows was shown at trial to be abhorrent. As a result, we are exploring our options. This is far from over.”
Barred by legal precedent governing awards for damages, Forst seemed to call for another resolution to the long-running case.
In a footnote to the five-page ruling he wrote, “Just as the bar disciplinary process was utilized to punish the deceptive attorneys in this case, perhaps there is a non-judicial mechanism, outside of our purview, to similarly punish the attorneys' partners-in-deception, the buyers.”
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllAfter Miami Arrest, Top Real Estate Broker Brothers Facing Sex Crimes Charges
US Judge Throws Out Sale of Infowars to The Onion. But That's Not the End of the Road for Sandy Hook Families
4 minute read3 Incidents Lead to Charges Against the Alexander Brothers; Cousin Remains at Large
3 minute readAmid Growing Litigation Volume, Don't Expect UnitedHealthcare to Change Its Stripes After CEO's Killing
6 minute readTrending Stories
- 1What Does Ohio Supreme Court's Opioid Decision Mean for Public Nuisance Claims?
- 2Bucking Industry Trend, Sidley Austin Elects Biggest Class of Partners in Firm History
- 3US Judge Throws Out Sale of Infowars to The Onion. But That's Not the End of the Road for Sandy Hook Families
- 4‘Really Deflating’: Judges React to Biden Threat to Veto New Judgeships Bill
- 53 Incidents Lead to Charges Against the Alexander Brothers; Cousin Remains at Large
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250