Powell

INTRODUCTION

Lupe Powell’s daughter, Lucie Idleman, bought a house with her friend and business partner, Jonathan Christodoro. The partners planned to remodel and resell the house within a few months. Not long into the project, Idleman, without informing Christodoro, asked Powell to provide additional funding. Idleman subsequently abandoned the project, Powell came forward and contributed her time and almost $300,000 to complete the renovation, and the house eventually sold 18 months after Idleman and Christodoro bought it. Powell sued her daughter (who later filed for bankruptcy) and Christodoro to recover her expenditures. Christodoro filed a cross-complaint against Powell for aiding and abetting Idleman’s breach of fiduciary duty, fraudulent concealment, and constructive fraud. Christodoro alleged Idleman did not obtain permits for the project, used unlicensed construction workers, and got her mother involved in the renovation, all without Christodoro’s knowledge or consent. Christodoro alleged that, as a result, he lost money on the project. A jury awarded Powell nothing on her complaint, and awarded Christodoro $107,374.21 on his cross-complaint. Powell appeals, arguing that…