Ruddock v. First National Bank of Lake Forest

Martin Ruddock (plaintiff) purchased a rare astronomical clock from First National Bank of Lake Forest (First National) (defendant), which was acting as guardian of an estate, at a public sale. Elmer and Pauline Crum (defendants) had earlier been given a right of first refusal by First National. When an officer of First National informed the Crums that the clock had been sold, the Crums threatened litigation. First National then refused Ruddock’s tender of $7,000 and sold the clock to the Crums. Ruddock filed a suit against the bank, seeking damages so he could purchase the clock from the Crums. After a failed attempt to negotiate a purchase with the Crums, Ruddock amended his complaint, seeking specific performance against the Crums. The Crums argued that, as bona fide purchasers, their property interest was protected. Additionally, the Crums raised an affirmative defense of laches to the claim for specific performance. At the time of trial, the clock’s estimated value was $40,000. The trial court entered judgment against the bank in the amount of $28,000 but found that the Crums were bona fide purchasers for value and denied Ruddock’s request for specific performance. Ruddock appealed, arguing that the Crums should not have been considered bona fide purchasers, because they were aware of his purchase of the clock. On appeal, the Crums argued that specific performance was only appropriate for real property, not personal property. The Crums maintained their laches argument on appeal, contending that Ruddock waited too long to file his claim, and that the clock’s appreciation in value necessitated application of the laches doctrine to prevent unfairness.