14 May 2015

Negligence: Norris Ward McKinnon v. Kaye

Lawyers are under no obligation to offer unsought advice on the wisdom of a business transaction and neither are they responsible for client losses suffered when trying to extricate them from contracts previously entered into.
Hamilton solictors, Norris Ward McKinnon, were asked by new clients, a Mr and Mrs Kaye to sort out a bungled 2005 purchase of the franchised Palmers Garden Centre in Cambridge.  A different Hamilton law firm, Tanner Fitzgerald Getty, had acted for them on the initial purchase.  There were allegations of negligence after $725,000 was paid for land occupied by the business without Tanner Fitzgerald securing title to the premises – title which was needed for registration of a mortgage to Southland Building Society funding the purchase.  The Kayes were able to take possession of the business initially only under a licence to occupy.  This cost them $2840 per month in rent.  Adjustments to the remainder of the $449,000 contract price still had to be fixed by a valuer looking at goodwill, stock and plant. Penalty interest was escalating while the Kayes refused to make any further payment until adjustments were made.  Their business venture eventually failed, being sold at a mortgagee sale in April 2009.
Matters reached the High Court when Norris Ward McKinnon sued the Kayes for $70,000 in unpaid fees.  The Kayes counterclaimed for $2.5 million saying Norris Ward had failed to do their job properly: failing to promptly secure a cost-efficient resolution of the legal issues they faced, failing to suggest Alternative Dispute Resolution procedures, and failing to properly advise the true extent of Tanner Fitzgerald’s earlier negligence.
Justice Peters ruled Norris Ward had properly carried out the Kayes’ instructions to sort out the earlier botched purchase.  The Kayes appeared to believe, she said, that lawyers are not doing their job properly if they are unable to extricate clients from contracts already entered into or to negotiate more advantageous outcomes from an existing contractual commitment.
However, Justice Peters ruled Norris Ward was negligent in not clearly specifying the level of damages likely to be recoverable from Tanner Fitzgerald for that law firm’s earlier negligence.  The Kayes were seeking $1.8 million in damages from Tanner Fizgerald.  Initially, Norris Ward led them to believe they would get damages “in the hundreds of thousands of dollars”.  Later expert advice was that the Kayes would get at best $60,000 to $70,000 with a deduction for their own contributory negligence.  Evidence was given that the Kayes accepted $90,000 from Tanner Fitzgerald in 2009 in an out of court settlement as full payment of their claim.  Justice Peters ruled that a reasonably competent lawyer would have advised the Kayes at an earlier stage that the amount claimed from Tanner Fitzgerald was excessive.  But even if negligent in not giving accurate advice sooner, this negligence did not cause any loss to the Kayes, she said.
Norris Ward McKinnon v. Kaye – High Court (14.05.15)
15.047