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Armstrong v. Csurilla

New Mexico Supreme Court
817 P.2d 1221 (1991)


Facts

William and Josephine Csurilla (defendants) agreed to purchase a gasoline station and adjacent property from Calvin and Dorothy Armstrong (plaintiffs). The combined contract price for both properties was $231,594. Shortly after the sale contracts were executed, the Csurillas failed to make payments under the gas-station contract. The Csurillas continued to run the gas station for a short period of time before closing it a few months later. By the time the Armstrongs repossessed the gas station the following year, it was in severe disrepair and had significantly diminished in value. The Armstrongs brought suit against the Csurillas for breach of contract. The trial court found that the Csurillas had breached the contracts for both properties, and ordered foreclosure. In a judicial sale, the Armstrongs purchased both properties for a total price of $90,000. The Csurillas objected, arguing that the sale should not be confirmed, based on the extreme disparity between the sale price and the actual values of the properties. At a hearing on the issue, the Csurillas did not proffer any evidence establishing the actual values of the properties and had not conducted any formal appraisals. The trial court determined that the sale was fair, ordered confirmation, and entered a significant deficiency judgment against the Csurillas. The Csurillas appealed.

Rule of Law

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Issue

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Holding and Reasoning (Montgomery, J.)

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  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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