Chambers v. Scofield
247 P.3d 982
Alaska2011Background
- Chambers purchased a triplex from Carley in 2006.
- Carley’s daughters Scofield and Covington were appointed guardians in 2007 due to Carley’s mental condition.
- In 2008 the parties settled, rescinding the sale and restoring positions as if no sale occurred, including credits and payment obligations.
- Settlement required Scofield to credit Chambers for rents received and pay various sums, including the “fair market costs” of Chambers’s repairs and improvements.
- To determine fair market costs, the parties selected a neutral remodel appraiser; Halsey was ultimately chosen by Scofield’s side and later replaced due to methodological concerns.
- A second appraiser, Roberts, conducted a new inspection and issued a lengthy report; the court held a second evidentiary hearing, calculating a final fair market cost of repairs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 'fair market cost' includes profit/overhead | Chambers argues it does include profit/overhead for supervising the work. | Scofield argues 'fair market cost' excludes profit/overhead absent explicit agreement. | No; no industry standard supports including profit/overhead. |
| Whether the court properly denied Chambers prevailing party status | Chambers contends he prevailed on core issues and should be prevailing party. | Scofield argues neither party prevailed overall due to mixed outcomes. | No abuse of discretion; neither party was prevailing party overall. |
Key Cases Cited
- Kazan v. Dough Boys, Inc., 201 P.3d 508 (Alaska 2009) (contract interpretation and settlement enforceability considerations)
- Gaston v. Gaston, 954 P.2d 572 (Alaska 1998) (settlement agreements interpreted as contracts)
- Fernandes v. Portwine, 56 P.3d 1 (Alaska 2002) (prevailing party determinations under Rule 82 reviewed for abuse of discretion)
- Haskins v. Shelden, 558 P.2d 487 (Alaska 1976) (abuse of discretion standard for fee awards under Rule 82)
- Rockstad v. Erikson, 113 P.3d 1215 (Alaska 2005) (contract interpretation and independent review of interpretation)
- City of Valdez v. Valdez Dev. Co., 523 P.2d 177 (Alaska 1974) (prevailing party and fee-shifting principles in Alaska)
- Hooper v. Hooper, 188 P.3d 681 (Alaska 2008) (standards for reviewing contract and fee-related decisions)