Angle, R. v. Smith, A., Angle, R. v. Smith, A. No. 1934 EDA 2016

Background

In 2009 the Smiths purchased property from the Angles under an installment land contract: $149,500 purchase price, $7,500 down, $1,370.34/mo, 10% interest for 20 years; buyers responsible for taxes and upkeep.
In Jan. 2013 the Department of Banking entered a consent order finding the 10% interest unlawful and required the seller to amend the contract; the Angles prepared an amended agreement but the Smiths refused to sign.
The Smiths fell behind: unpaid 2013 taxes ($2,271.19) and four months of payments (June–Sept. 2013, $5,481.36). They vacated the property in Oct. 2013.
On Oct. 15, 2013 the Smiths’ counsel sent a letter offering $7,500 in full satisfaction; the Angles accepted (phone message and written letter). On Oct. 24 counsel sent a corrective letter claiming the offer should have been $500.
Plaintiff filed suit for breach of the settlement; after arbitration and remand the trial court held a non-jury trial and awarded the Angles $7,740.19 on breach of contract and quantum meruit theories. The Superior Court affirmed.

Issues

Issue	Plaintiff's Argument (Angle)	Defendant's Argument (Smith)	Held
Whether a binding settlement contract existed for $7,500	Molnar’s Oct. 15 letter was an authorized offer; Angle accepted by phone/written letter; consideration existed (discharge of unpaid taxes/payments).	Molnar lacked authority and the $7,500 was a mistake (corrected to $500); no valid acceptance/authority.	Court found offer, valid acceptance (mailbox rule/phone) and consideration; settlement was binding.
Whether the original installment sale was void and its consequences	Angle acknowledged Dept. of Banking order but argued remedyable/secondary to settlement/quantum meruit recovery.	Smiths argued the contract was void under the Consent Agreement, making enforcement and liquidated damages provisions unenforceable.	Court held the Sales Agreement’s illegal interest provision voided the contract as of the Consent Agreement date, nullifying contract provisions (so notice provision and liquidated-damages argument failed).
Whether quantum meruit recovery was available and amount	Even if no settlement, Angle conferred benefit (free occupancy, unpaid taxes) and is entitled to restitution; rental value approximated monthly payment.	Smiths argued payments included principal/interest, improvements should offset damages, and taxes/payment months disputed.	Court held unjust enrichment proven; accepted Angle’s credibility and calculations and awarded ~$7,740.19.
Whether damages calculation improperly omitted credits (downpayment/improvements/payments)	Angle calculated unpaid rent and taxes; award approximated either measure (settlement or sums due).	Smiths sought credit for $7,500 down payment, alleged $5,000 improvements, and other post-bankruptcy payments.	Court found no admissible proof of credits; rejected Mrs. Smith’s testimony as not credible; damages calculation affirmed.

Key Cases Cited

Wyatt Inc. v. Citizens Bank, 976 A.2d 557 (Pa. Super. 2009) (standard of review for bench-trial findings)
Hart v. Arnold, 884 A.2d 316 (Pa. Super. 2005) (elements of breach of contract)
Reutzel v. Douglas, 870 A.2d 787 (Pa. 2005) (attorney must have client authority to bind client in settlement)
Breza v. Don Farr Moving & Storage Co., 828 A.2d 1131 (Pa. Super. 2003) (mailbox rule presumption of receipt)
Kraemer v. Schaeffer, 751 A.2d 241 (Pa. Super. 2000) (unilateral mistake cannot rescind accepted settlement)
Omicron Sys., Inc. v. Weiner, 860 A.2d 554 (Pa. Super. 2004) (fact-finder’s role in assessing and estimating damages)