Melvin and Gladys Crouse v. John Hobday, Jr. and Hobday Custom Homes
15-1186
| W. Va. | Nov 21, 2016Background
- In May 2012 Melvin and Gladys Crouse (pro se) sued John Hobday Jr. and Hobday Custom Homes in Morgan County Magistrate Court for breach of contract stemming from a home renovation.
- Magistrate Court held a nonjury proceeding on July 10, 2012 and entered judgment for respondents; petitioners did not appeal that magistrate ruling.
- In November 2012 petitioners filed the same claim in Morgan County Circuit Court; respondents moved for summary judgment based on res judicata and the circuit court granted summary judgment in December 2013.
- This Court remanded for an evidentiary hearing to determine whether a bench trial actually occurred in magistrate court; the circuit court held a hearing in August 2015 (including magistrate deposition) and reconsidered summary judgment.
- The circuit court again granted summary judgment, finding the magistrate conducted a bench trial and thus there was a final adjudication on the merits; the Supreme Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether res judicata bars the circuit action because of a prior magistrate adjudication | Crouse: No final adjudication occurred in magistrate court — no bench trial, brief hearing, no testimony/cross-examination, no recording | Hobday: Magistrate conducted a bench trial (parties sworn, testified, exhibits offered, rulings made) and entered judgment; thus claim precluded | Held: Magistrate conducted a bench trial and entered final adjudication; res judicata bars the circuit action |
| Whether magistrate court had jurisdiction over the prior action | Crouse: (did not argue lack of jurisdiction) | Hobday: Magistrate court had jurisdiction over the matter | Held: Magistrate court had jurisdiction (undisputed) |
| Whether factual disputes about the magistrate proceeding create a genuine issue precluding summary judgment | Crouse: Conflicting evidence about what happened at magistrate proceeding raises material fact | Hobday: Disputed facts concern prior adjudication — a legal issue for the court, not a trialworthy fact for summary judgment | Held: Discrepancies do not preclude summary judgment; determination of res judicata is a question of law for the court |
Key Cases Cited
- Painter v. Peavy, 192 W.Va. 189, 451 S.E.2d 755 (summary judgment reviewed de novo)
- Blake v. Charleston Area Medical Center, Inc., 201 W.Va. 469, 498 S.E.2d 41 (elements required to invoke res judicata)
- Jividen v. Law, 194 W.Va. 705, 461 S.E.2d 451 (definition of a "genuine issue" for summary judgment)
- Aetna Cas. & Sur. Co. v. Federal Ins. Co. of New York, 148 W.Va. 160, 133 S.E.2d 770 (standard for granting summary judgment when no genuine issue exists)
- Charleston Nat. Bank v. Hulme, 117 W.Va. 790, 188 S.E. 225 (res judicata matters are questions of law for the court)