Bank of America v. JB Hanna, LLC, No. 16-2088 (8th Cir. 2017)
Annotate this CaseBank of America filed suit against the Hanna Parties for breach of contract after they failed to pay a loan. The jury found that the Hanna Parties did not breach the contract and the district court entered judgment for them. On remand, the Hanna Parties advanced defenses of fraudulent inducement and fraudulent failure to disclose. The Eighth Circuit affirmed the district court's grant of the Bank's motion for summary judgment on those defenses because JB Hanna could not have reasonably relied on the Bank's allegedly fraudulent representations. In this case, the district court correctly rejected the defenses of fraudulent inducement and fraudulent failure to disclose as a matter of law. Furthermore, because there was insufficient evidence to support the fraud defenses, the setoff defense also failed.
Court Description: Colloton, Beam and Benton, Circuit Judges] Civil case - Contracts. For the court's prior opinion in the matter, see Bank of Am., N.A. v. JB Hanna, LLC, 766 F.3d 841 (8th Cir. 2014). In a complex loan arrangement, the district court did not err in granting summary judgment for the Bank on defendants' fraud defenses as the defendants could not reasonably rely on the Bank's alleged misrepresentations; the undisputed facts show that Bank was not defendants' fiduciary, that defendants were experienced in this type of agreements, had sophisticated representation and could determine for themselves whether they should enter in particular transaction.
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