In the case of Swinton Home Care, LLC v. Lillian Tayman, Swinton, a home health care provider, sued Tayman and her deceased sister’s estate for breach of contract, quantum meruit, and unjust enrichment.
The case arose from a situation where Swinton’s representative convinced Lillian Tayman to sign a contract on behalf of her sister, Mary Tayman, even though she did not have the authority to do so. Mary Tayman paid for the services for a while, then defaulted, and subsequently died.
The Circuit Court for Montgomery County found that Swinton fraudulently induced Lillian Tayman to sign the contract, thereby voiding the contract and eliminating any obligation to guarantee. In Maryland, fraudulent inducement refers to “a situation where a person is induced by some fraudulent representation or pretense to execute the very instrument which is intended to be executed[.]” Meyers v. Murphy, 181 Md. 98, 100 (1942). Fraud must be demonstrated by clear and convincing evidence, which is a higher evidentiary bar than the typical civil action.
The court ruled in favor of the Taymans. On appeal, Swinton challenged the sufficiency of the evidence supporting this decision, but the judgment was affirmed. This case is relevant for clients as it highlights the legal consequences of inducing someone to sign a contract without proper authority, and how such actions can lead to a contract being voided.
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