A-15-0408, Rodney Heinen (Appellant) v. Corey Snethen and Jack R. Rieger, individually and d/b/a C&J Farms
Richardson County, District Court Judge Daniel E. Bryan, Jr.
Attorney for Appellant: David A. Domina, Christian T. Williams (Domina Law Group, pc llo); Richard H. Hoch (Hoch Law Office, LLC)
Attorney for Appellee: Stephen D. Mossman, Ryan K. McIntosh (Mattson Ricketts Law Firm)
Civil Action: Breach of Lease Agreement
Action Taken by Trial Court: The trial court found that Heinen had breached the lease agreement and made fraudulent misrepresentations. The trial court held that Snethen and Rieger were not entitled to damages because they failed to present evidence of their efforts to mitigate damages.
Assignments of Error on Appeal: On appeal, Heinen argues that (1) the trial court erred in interpreting the lease and finding that eligibility to enroll in a federal farming assistance program was a material term, (2) the trial court erred in finding Heinen breached the lease, (3) the trial court erred in failing to find that Snethen and Rieger breached the lease, and (4) the trial court erred in finding that Heinen made fraudulent misrepresentations prior to the parties entering into the lease. On cross-appeal, Snethen and Rieger argue that the trial court erred in failing to award them damages for Heinen's breach of the lease.
Extended Case Summary (for Educational Purposes):
A-15-0408, Rodney Heinen (Appellant) v. Corey Snethen and Jack R. Rieger, individually and d/b/a C&J Farms
Richardson County, District Court Judge Daniel E. Bryan, Jr.
Attorney for Appellant: David A. Domina, Christian T. Williams (DominaLaw Group, pc llo); Richard H. Hoch (Hoch Law Office, LLC)
Attorney for Appellee: Stephen D. Mossman, Ryan K. McIntosh (Mattson Ricketts Law Firm)
Civil Action: Breach of Lease Agreement
Action Taken by Trial Court: The trial court found that the landowner, Heinen, had breached a lease agreement with the renters, Snethen and Rieger, and that Heinen made fraudulent misrepresentations about whether the land could be enrolled in a federal farming program. The trial court held that Snethen and Rieger were not entitled to damages, however, because they failed to present evidence of their efforts to mitigate damages.
Assignments of Error on Appeal: On appeal, Heinen argues that (1) the trial court erred in interpreting the lease and finding that eligibility to enroll in a federal farming assistance program was a material term, (2) the trial court erred in finding Heinen breached the lease, (3) the trial court erred in failing to find that Snethen and Rieger breached the lease, and (4) the trial court erred in finding that Heinen made fraudulent misrepresentations prior to the parties' entering into the lease. On cross-appeal, Snethen and Rieger argue that the trial court erred in failing to award them damages for Heinen's breach of the lease.
Facts: Heinen leased farmland to Snethen and Rieger in March 2013 pursuant to a written lease. The lease provided that Snethen and Rieger would rent and farm the land for 3 years. In February 2014, 1 year into the lease, Snethen and Rieger informed Heinen that they would no longer be renting the land.
Heinen brought suit against Snethen and Rieger, alleging that they had breached the lease agreement by failing to pay rent for the second year of the lease term. Snethen and Rieger filed an answer and counterclaim, contending that Heinen had lied about the land's eligibility to be enrolled in a federal farming subsidy program and that Heinen had therefore breached the lease first.
The district court found that Heinen breached the lease agreement. According to the district court, the written document that contained the lease was an ambiguous contract, but the parties' actions indicated that being able to enroll the rented lands in the federal farming program was a material term of the lease. Heinen had breached this term of the lease because he had violated a federal law, rendering Snethen and Rieger unable to enroll his lands in the program.
Despite finding that Heinen had breached the lease, the district court did not award Snethen and Rieger monetary damages. The court held that Snethen and Rieger had not proven that they mitigated their damages after Heinen had breached the lease and that this precluded them from receiving damages.
Heinen appealed the district court's order, and Snethen and Rieger cross-appealed. On appeal, Heinen argues that Snethen and Rieger breached the lease by failing to pay rent. In support of his argument, Heinen claims that the ability to enroll the land in the federal farming program should not be considered a term of the lease.
On cross-appeal, Snethen and Rieger argue that the district court correctly found that Heinen had breached the lease, but that they should be entitled to damages as a result of Heinen's breach. Snethen and Rieger argue that they should not have been assigned the burden to prove that they mitigated their damages.