Vreeman v. Davis
1984 Minn. LEXIS 1356, 348 N.W.2d 756, 38 U.C.C. Rep. Serv. (West) 850 (1984)
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Rule of Law:
A property owner is competent to express an opinion on the market value of their property, and this testimony, even if it alleges the property has zero value, is ordinarily sufficient to create a jury question on damages. Any weaknesses in the foundation for the owner's opinion go to its weight, not its admissibility as a matter of law.
Facts:
- In March 1978, Joseph Vreeman purchased a new mobile home manufactured by Champion Home Builders, Inc. for $16,900.
- Vreeman had comparison-shopped for a year before making the purchase.
- Shortly after the mobile home was installed, Vreeman discovered that it leaked whenever it rained.
- Vreeman and his family lived in the home for approximately two and a half years, during which they attempted various repairs.
- By December 1980, Vreeman considered the home to be no longer fit to live in.
- Vreeman and his family subsequently moved out of the mobile home.
Procedural Posture:
- Joseph Vreeman sued the manufacturer, Champion Home Builders, Inc., and the local dealer in a Minnesota state trial court.
- A default judgment was entered against the dealer.
- The case against Champion Home Builders proceeded to a jury trial.
- At the close of all evidence, the trial court granted Champion's motion for a directed verdict, ruling that Vreeman had failed to prove general damages as a matter of law.
- Vreeman, as plaintiff-appellant, appealed the directed verdict to the Minnesota Supreme Court.
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Issue:
Is a property owner's testimony that their defective property has a market value of zero sufficient, by itself, to create a jury question on general damages for breach of warranty?
Opinions:
Majority - Simonett, J.
Yes, a property owner's testimony that their property has a market value of zero is sufficient to create a jury question. The court held that an owner is competent to express an opinion on the market value of their property, and any weakness in the foundation for that opinion goes to its weight for the jury to consider, not its admissibility for a judge to decide as a matter of law. Here, Vreeman's comparison-shopping for a year provided a sufficient foundation for his opinion to have probative value. The trial court erred in rejecting his opinion of zero value as a matter of law based on an assumption of salvage value. If Champion Home Builders believed the home had salvage value, it had the opportunity and burden to present evidence to that effect; by choosing not to, it cannot now complain about the lack of such evidence. Furthermore, the court noted that latent defects which only become apparent over time constitute 'special circumstances' under Minn. Stat. § 336.2-714, allowing damages to be measured at a later date than the time of acceptance.
Analysis:
This decision reinforces the established principle that property owners are presumed competent to testify as to the value of their own property. It clarifies that such testimony, even an extreme opinion like 'zero value,' is sufficient to survive a directed verdict and allow the issue of damages to be decided by a jury. The ruling effectively places the burden on the defendant to rebut an owner's valuation with contrary evidence, such as proof of salvage value, rather than allowing a case to be dismissed merely because the owner's valuation seems incredible to a judge. This strengthens the position of consumer plaintiffs in breach of warranty actions by lowering the evidentiary bar for getting the damages question to a jury.
