Gordon H. Crafts and Jaymie V. Crafts v. David Pitts

Summary

The Supreme Court of Washington held that the Crafts' action for specific performance of a real property contract survived David Pitts's Chapter 7 bankruptcy discharge. Because the 9.83-acre parcel was unique and money damages could not adequately compensate the Crafts, the equitable claim was not a dischargeable claim under the Bankruptcy Code. The court affirmed the order requiring Pitts to quitclaim his interest in the property.

Holdings

1. An equitable claim for specific performance survives a bankruptcy discharge when the underlying breach does not give rise to a right to money damages that would adequately and completely compensate the claimant.
2. Specific performance was appropriate because the 9.83-acre parcel was unique, adjoining the Crafts' existing property, and could not be adequately replaced or valued through money damages.
3. Pitts breached a clear and definite contractual obligation to execute and deliver a quitclaim deed, and the trial court properly ordered him to quitclaim his interest in the 9.83 acres.

Questions Presented

1. Whether the Crafts' action for specific performance of Pitts' obligation to convey the 9.83-acre parcel was discharged by Pitts' Chapter 7 bankruptcy.
2. Whether money damages were an adequate and complete alternative remedy such that the equitable claim constituted a dischargeable bankruptcy claim.
3. Whether specific performance was an appropriate remedy for Pitts' breach of the lease provision requiring delivery of the quitclaim deed.

Disposition

affirmed