Commercial Flooring & Mini Blinds, Inc. v. Edenfield
138 So. 3d 30
La. Ct. App.2014Background
- CFMB-Inc. owned half of CFMB-BR; Pat Rooney and Keith Edenfleld managed Baton Rouge operations.
- Roonfield Properties, L.L.C. owned 50/50 by Pat and Keith, leased the Airline Highway property to CFMB-BR.
- In 2007, Pat sold his 50% in Roonfield to Keith for $500,000; Keith then claimed ownership of all Baton Rouge assets.
- Keith formed CF-BR and transferred CFMB-BR assets to CF-BR; Pat allegedly learned of the transfer in 2008.
- CFMB-Inc. and CFMB-BR sued Keith and CF-BR for wrongful conversion of CFMB-Inc.’s half of CFMB-BR’s assets.
- Jury awarded $601,330 in damages; court later amended to $494,640.66 after considering debt payoff related to the conversion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there an oral sale of CFMB-Inc.’s interest? | Pat sold only Roonfield half to Keith. | There was an oral agreement for the entire Baton Rouge operation to be transferred to Keith. | No manifest error: no oral agreement proved; sale not established. |
| Did Keith and CF-BR wrongfully convert CFMB-Inc.’s half of CFMB-BR’s assets? | CFMB-Inc. retained half and assets were transferred without authority. | Assets were lawfully transferred and debts paid; no conversion by CF-BR. | Conversion proven; assets transferred without CFMB-Inc. authority. |
| Are damages properly calculated for conversion? | Value of CFMB-Inc.’s share determined by expert testimony; full value awarded. | Debt payments should reduce damages; trial court erred in admitting valuation methods. | Damages reduced by debt payoff; amended total $494,640.66. |
Key Cases Cited
- Rosell v. ESCO, 549 So.2d 840 (La. 1989) (standard for reviewing factual findings and credibility)
- Stobart v. State through Dept. of Transp. and Development, 617 So.2d 880 (La. 1993) (reasonable/credible inferences in evaluating evidence)
- Dual Drilling Co. v. Mills Equipment Investments, Inc., 721 So.2d 853 (La. 1998) (conversion elements and damages framework)
- Pennington Const., Inc. v. R A Eagle Corp., 652 So.2d 637 (La. App. 1st Cir. 1995) (corroboration required for contract proof)
- Townsend v. Urie, 800 So.2d 11 (La. App. 1st Cir. 2001) (factual findings and credibility on contract issues)
- Hanks v. Entergy Corp., 944 So.2d 564 (La. 2006) (credibility and abuse-of-discretion standards in expert testimony)
- Guillory v. Lee, 16 So.3d 1104 (La. 2009) (jury’s discretion in determining damages and admissibility of expert testimony)
- Callison v. Livingston Timber, Inc., 849 So.2d 649 (La. App. 1st Cir. 2003) (trial court broad discretion on expert testimony)
- Williams v. Our Lady of the Lake Hosp., Inc., 22 So.3d 997 (La. App. 1st Cir. 2009) (appeal deferential to jury credibility determinations)
- Matherne v. Terrebonne Parish Police Jury, 462 So.2d 274 (La. App. 1st Cir. 1984) (measure of damages in civil cases)
- Gurst v. City of Natchitoches, 428 So.2d 502 (La. App. 3d Cir. 1983) (valuation principles in misappropriation contexts)