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Staats v. Praegitzer

Oregon Court of Appeals
Jun 19, 1984
679 P.2d 334 (Or. Ct. App. 1984)

Summary

In Staats, this court held that the plaintiff waived her right to strict foreclosure because she accepted late installment payments after she knew that the defendant was delinquent in paying property taxes.

Summary of this case from Shirley v. Tolbert

Opinion

29075; CA A27922

Argued and submitted January 23, 1984 Reversed April 11, 1984 Reconsideration denied May 25, 1984

Petition for review denied June 19, 1984

Appeal from Circuit Court, Polk County.

Donald R. Blensly, Judge.

Joseph E. Penna, Monmouth, argued the cause and filed the brief for appellant.

Willard L. Cushing, McMinnville, argued the cause for respondent. With him on the brief was Cushing, Johnstone Peterson, P.C., McMinnville.

Before Richardson, Presiding Judge, Joseph, Chief Judge, and Newman, Judge.

JOSEPH, C. J.

Reversed.


Defendant appeals from a decree of strict foreclosure of a land sale contract. We reverse.

The contract contains a time-essence clause and a nonwaiver of rights clause and requires defendant purchaser to pay the real property taxes when due. Defendant did not pay those taxes for the years 1979-1980 and 1980-1981. Plaintiff mailed notice of that delinquency to defendant on or about October 2, 1980. Notice was given according to the terms of the contract, but defendant never received it. Plaintiff accepted 10 monthly installment payments after mailing the notice to defendant. Defendant first became actually aware of plaintiff's concern about the delinquent taxes when he was served with a copy of the complaint on September 10, 1981. Four days later he paid all delinquent taxes.

The trial court granted plaintiff a decree of strict foreclosure and rejected defendant's argument that he was not given sufficient notice of default. The court found that notice was sent in accordance with the terms of the contract and was sufficient. The trial court also rejected defendant's argument that plaintiff had waived her right to strict foreclosure by accepting the monthly payments after the mailing of the notice. The court reasoned that plaintiff did not waive her right to foreclose by accepting the payments, because defendant, as purchaser, did not rely on plaintiff's actions "so as to be lulled into a false sense of security that strict compliance with the provisions of the contract [would not be] required."

We disagree with the trial court's characterization of waiver. Although plaintiff's notice of default was adequate under the terms of the contract, her subsequent acceptance of monthly installment payments is conduct that constitutes waiver of her right to strict foreclosure without giving defendant further notice of default, allowing a reasonable opportunity to cure the default and informing defendant that strict performance of that contract provision will thereafter be required. See Fisher v. Tiffin, 275 Or. 437, 440, 551 P.2d 1061 (1976); Wright v. Assoc. Financial Services, 59 Or. App. 688, 694, 651 P.2d 1368 (1982); Phair v. Walker, 48 Or. App. 641, 646, 617 P.2d 616 (1980); but see Lorenzen v. Jackson, 284 Or. 251, 586 P.2d 341 (1978).

Reversed.


Summaries of

Staats v. Praegitzer

Oregon Court of Appeals
Jun 19, 1984
679 P.2d 334 (Or. Ct. App. 1984)

In Staats, this court held that the plaintiff waived her right to strict foreclosure because she accepted late installment payments after she knew that the defendant was delinquent in paying property taxes.

Summary of this case from Shirley v. Tolbert

In Staats and Auernheimer, the plaintiffs, after learning of the defendants' failure to pay taxes and thus of their immediate right to foreclose, did not take the necessary steps to enforce that right. Rather, by accepting payments on the outstanding balance, they treated the payment provisions of the land sale contracts as still being controlling.

Summary of this case from Alderman v. Davidson

In Staats, the plaintiff mailed notice of the defendant's delinquency in paying taxes on October 2, 1980, but the defendant never received the notice.

Summary of this case from Alderman v. Davidson

In Staats v. Praegitzer, 67 Or. App. 543, 679 P.2d 334, rev den 297 Or. 339 (1984), the contract contained a time-essence clause that required the defendant purchaser to pay the real property taxes when due. He did not pay the taxes for two years.

Summary of this case from Auernheimer v. Metzen

In Staats v. Praegitzer, 67 Or. App. 543, 679 P.2d 334, rev den 297 Or. 339 (1984), we held that the plaintiff had waived her right to strict foreclosure by accepting the benefit of the defendants' timely installment payments after declaring the defendants in default for failing to pay taxes.

Summary of this case from Auernheimer v. Metzen

In Staats, the plaintiff's actions were inconsistent with the right to accelerate the contract, because she had accepted payments after declaring the contract in default.

Summary of this case from Auernheimer v. Metzen
Case details for

Staats v. Praegitzer

Case Details

Full title:STAATS, Respondent, v. PRAEGITZER, Appellant

Court:Oregon Court of Appeals

Date published: Jun 19, 1984

Citations

679 P.2d 334 (Or. Ct. App. 1984)
679 P.2d 334

Citing Cases

Shirley v. Tolbert

" Id. Defendant relies upon Staats v. Praegitzer, 67 Or. App. 543, 679 P.2d 334, rev den 297 Or. 339 (1984),…

Auernheimer v. Metzen

The issue is whether he waived the right to exercise the time-of-the-essence provision by accepting three…