Unambiguous Contract Must Be Enforced as Written

Lafayette Land Acquisitions II, LLC v. Walls, [Ms. SC-2022-0765, Apr. 21, 2023] __ So. 3d __ (Ala. 2023). The Court (Mitchell, J.; Parker, C.J., and Mendheim, Stewart, and Cook, JJ., concur; Shaw, J., concurs in the result, which Wise and Bryan, JJ., join; Sellers, J., concurs in the result) reverses the Baldwin Circuit Court’s ore tenus judgment declaring the due diligence period had ended and the subject real estate sales contract had expired.

The Court reiterates that “‘[i]f a contract can be interpreted without going beyond the four corners of the document, the trial court’s resolution of the question of law is accorded no presumption of correctness, and this Court’s review is de novo.’ Exxon Mobil Corp. v. Alabama Dep’t of Conservation & Nat. Res., 986 So. 2d 1093, 1101 (Ala. 2007).” Ms. *6. Based on the unambiguous language of the agreement, the Court concludes the buyer “never rejected the deal to purchase the property in writing and was willing to close on the date specified in the purchase agreement, the parties are obligated to close. The circuit court erred when it concluded that the purchase agreement had ‘expired’ and that, as a result, neither party owed a duty to the other.” Ms. *9.

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