Appeal from the Iowa District Court for Muscatine County, Gary D. McKenrick, Judge.
Plaintiffs appeal the district court's grant of defendant's motion for directed verdict.
Patrick L. Woodward of McDonald, Woodward & Carlson, P.C., Davenport, for appellants.
Roger A. Huddle of Weaver & Huddle, Wapello, for appellee.
Considered by Doyle, P.J., and Danilson and Mullins, JJ.
Plaintiffs, Elizabeth Hackett and Joseph Gaeta, appeal the district court's grant of defendant Charles J. Gaeta's motion for directed verdict in this action for intentional interference with contract and for attorney's fees incurred in dissolving a temporary injunction. Elizabeth and Joseph claim the court erred in concluding there was insufficient evidence to support certain essential elements of their claims. For the reasons stated below, we affirm the ruling of the district court.
I. BACKGROUND FACTS AND PROCEEDINGS.
The mother of all the parties to this proceeding died on January 4, 2011. The disposition of her assets and those of her husband, who died several years before, was governed largely by inter vivos trusts she and her husband had established. Each trust held an undivided one-half interest in two parcels of farm real estate. The trusts granted Charles an option to purchase any of the farm real estate, which was exercisable for six months from the date of death of the last settlor. The trust instruments provided that Charles's purchase price would be either that agreed upon by all of the siblings or, if no agreement could be reached, the value determined by an independent appraiser, subject to a $30, 000 credit in Charles's favor. If Charles did not timely exercise this option, the trust instruments provided for a sealed-bid auction for the real estate among the surviving siblings.
After the mother's death the parcels were appraised—one parcel of 169.85 acres valued at $755, 800 and one parcel of 189.56 acres valued at $644, 500. Before the six-month deadline Charles notified the estate that he wished to exercise his option, but he offered $300 per acre, less than 10% of the appraised value of the parcels. He maintains this was the price established by an oral agreement to purchase the real estate he and his father had entered into prior to his father's death. Because this offer did not comply with the requirements of the trust instruments, the attorney for the trusts concluded Charles had not properly exercised his option and offered the real estate for auction among the siblings. Charles thereafter filed a claim in probate of his right to purchase the real estate at the $300-per-acre price. The executors disallowed the claim, and the auction proceeded. Elizabeth was the successful bidder for one parcel, and Joseph for the other.
In the probate proceedings, Charles then filed a request for hearing on the disallowance of his claim, seeking (1) specific performance of the oral agreement with his father, (2) a declaratory judgment that the trust instruments required the siblings to hold a family conference to determine a sale price for the real estate before resorting to an independent appraisal, and (3) a temporary injunction enjoining the sale of the real estate to Elizabeth and Joseph pending resolution of those claims. The probate court issued the temporary injunction. Ruling later on the merits of the claim, the court denied the relief sought and dissolved the temporary injunction, allowing the sale of the real estate to proceed. Elizabeth and Joseph each closed on the real estate transactions in the spring of 2012, several months after the originally planned closing date of October 4, 2011.
Elizabeth and Joseph each brought actions against Charles for intentional interference with their contracts to purchase the farm real estate, and the cases were consolidated. They sought damages for legal fees and expenses in resisting Charles's claims and the burden of the delayed closings. They also sought an award of attorney's fees incurred in obtaining dissolution of the temporary injunction. At trial, Charles moved for a directed verdict at the close of the plaintiffs' case and renewed this motion at the close of all the evidence. The district court reserved its ruling on the motion and submitted the case to the jury. The jury found in favor of Elizabeth and Joseph on their intentional interference claims and on their request for an award of attorney's fees for dissolving the temporary injunction. Notwithstanding the jury's verdict, the district court subsequently granted the motion for directed verdict and entered judgment for Charles. Elizabeth and Joseph now appeal from that ruling.
II. SCOPE AND STANDARD OF REVIEW.
We review a trial court's ruling on a motion for directed verdict for errors at law. Schmitt v. Koehring Cranes, Inc., 798 N.W.2d 491, 494 (Iowa Ct. App. 2011). If substantial evidence exists to support each element of a claim, a motion for directed verdict must be overruled. Id. "Evidence is substantial when a reasonable mind would accept it as adequate to reach a conclusion." Godar v. Edwards, 588 N.W.2d 701, 705 (Iowa 1999) (citing Johnson v. Dodgen, 451 N.W.2d 168, 171 (Iowa 1990)). We must view all the evidence in the light most favorable to the ...