Everett Quinton v. Christie Cain and The Estate of Roger Cain (mem. dec.), 24A01-1706-CC-1271

In 2009 Everett Quinton leased ~100 acres to Roger and Christie Cain under a written rental contract with automatic renewal and a no-assignment/sublet clause; rent was typically $12,000 though the contract listed $10,000.
In October 2015 the Cains purchased and had Helena Chemical apply $19,978.09 of fertilizer and a cover (barley) crop to the leased land in preparation for 2016 farming.
Roger Cain died January 13, 2016. Christie arranged for Brad Tressler to farm the ground and testified she told Quinton in late January she would perform the lease and would have an agent pay rent; she said Quinton agreed.
Tressler visited Quinton in late February prepared to pay the March 1 rent on Christie’s behalf but testified Quinton refused to accept payment and tried to renegotiate price; Quinton contends no rent offer was made and he leased to Dirk Ricke on March 7, 2016.
Christie (individually and as personal representative of Roger’s estate) sued for breach of contract seeking the fertilizer cost; the trial court found Quinton breached, awarded $19,978.09 plus interest, and entered findings under Trial Rule 52(A).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Quinton breached the lease by renting to Ricke	Cain: Contract automatically renewed; Christie timely arranged performance and sent Tressler to pay rent, so Quinton’s re-leasing breached the contract	Quinton: No timely rent payment or valid offer; Christie effectively assigned/sublet to Tressler (prohibited), so Quinton could re-lease	Court: Findings supported that Tressler acted as Christie’s agent and attempted to pay; Quinton gave no demand for possession and rescission/termination was ineffective — breach affirmed
Whether plaintiffs were entitled to recover fertilizer cost as damages	Cain: Fertilizer was purchased in reasonable anticipation of farming the 2016 crop; loss is direct out-of-pocket damage from breach	Quinton: Damage award excessive / not supported	Court: Trial evidence supports the $19,978.09 fertilizer cost as within scope of damages; award affirmed

Gabriel v. Windsor, Inc., 843 N.E.2d 29 (Ind. Ct. App. 2006) (standard for reviewing Trial Rule 52(A) findings)
Quillen v. Quillen, 671 N.E.2d 98 (Ind. 1996) (findings are clearly erroneous only when record contains no supporting facts)
Fraley v. Minger, 829 N.E.2d 476 (Ind. 2005) (appellate review of conclusions of law is de novo)
Yanoff v. Muncy, 688 N.E.2d 1259 (Ind. 1997) (standard for reversing findings requires firm conviction a mistake was made)
Abernathy v. Bertram, 967 N.E.2d 510 (Ind. Ct. App. 2012) (damages review: affirm if within scope of evidence before the factfinder)