VINCENT METRO, LLC v. YAH REALTY, LLC, et al., SC 18486
Judicial District of New Haven
Bill of Interpleader; Whether the Trial Court Properly Dismissed this Interpleader Action as Moot in Light of the Defendants' Stipulation Regarding the Disposition of the Funds at Issue. The plaintiff and Yah Realty, LLC (Yah), entered into an agreement whereby the plaintiff would act as Yah's real estate broker and list Yah's property for sale. The plaintiff procured a potential buyer for the property, namely, John Fitzpatrick, and it accepted a $20,000 deposit from Fitzpatrick. After Fitzpatrick was unable to close on the property, the plaintiff brought this interpleader action against Yah, Fitzpatrick and Fitzpatrick's mother, who gave Fitzpatrick the deposit money. The plaintiff alleged that it had no claim to the $20,000 and that the defendants had made conflicting demands regarding the disposition of the funds. It therefore sought an order determining the defendants' rights to the funds and discharging it from any obligation to the defendants. The trial court entered an interlocutory judgment of interpleader, and the plaintiff deposited the funds with the court. The parties next filed cross motions for summary judgment. The defendants' motion was accompanied by a stipulation indicating that they had agreed that the funds should be released to Yah. In light of the defendants' stipulation, the trial court refrained from ruling on the cross motions for summary judgment and dismissed the action as moot. It stated that the plaintiff properly filed this interpleader action because the defendants initially made conflicting demands for the funds, but because the defendants agreed that the funds belong to Yah, the conflicting claims had been effectively resolved and there was no longer any practical relief that it could grant to the plaintiff. In this appeal, the plaintiff argues that the trial court improperly dismissed its action as moot because the defendants' stipulation did not resolve the issues of whether it should be discharged of any liability to the defendants and whether it is entitled to recover its costs and attorney's fees. The plaintiff also argues that the court should have rendered summary judgment in its favor because the interlocutory judgment of interpleader, as well as the undisputed evidence of the defendants' conflicting claims, conclusively established that it was a disinterested stakeholder with no corresponding liability to the defendants in connection with its handling of the funds.