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Housing Starts in U.S. Increased More Than Forecast in June
New-home construction in the U.S. rose more than forecast in June, providing some momentum for residential real estate near the end of its busy selling season.
Residential starts increased 4.8 percent to a 1.19 million annualized rate, the most since February, from 1.14 in May that was lower than previously estimated, Commerce Department data showed Tuesday in Washington. Permits, a proxy for future construction, also climbed.
The residential construction industry has remained in a steady but tepid recovery, struggling to make further progress as homebuilders run up against scarce land supply and credit standards stay tight in the eighth year after the last recession. At the same time, stable job gains and prospects for faster wage growth should buoy real-estate demand in the months ahead.
“The housing market continues to chug along quite nicely,” said Thomas Costerg, senior economist at Standard Chartered Bank in New York, whose projection was among the closest in the Bloomberg survey. “With mortgage rates so low, that provided an additional boost to the market, but at the same time we’re close to reaching cruise speed so I don’t think we’re expecting stellar performance going forward.”
The median forecast in a Bloomberg survey of 73 economists projected June starts at 1.165 million, little changed from the previously reported 1.164 million for May. Estimates ranged from 1.095 million to 1.2 million.
The starts data, while very volatile from month to month, have held in a narrow range over the past year, indicating residential real estate will have trouble adding to its post-recession rebound. Still, the report showed a wide range for error, with a 90 percent chance that last month’s figure was between an 8.7 percent decline and an 18.3 percent gain.
Permits climbed 1.5 percent to a 1.15 million annualized rate, matching the median forecast of economists surveyed by Bloomberg. Because the number of applications were lower than starts, it suggests it will be difficult to sustain last month’s gain in home building.
Beginning construction of single-family houses rose 4.4 percent to a 778,000 rate, the most since February, from 745,000 in May.
Groundbreaking on multifamily homes, such as townhouses and apartment buildings, climbed 5.4 percent to an annual rate of 411,000, the most since September. Data on these projects, which typically have led housing starts over the past few years, can be especially volatile.
Starts climbed in two of four regions, led by a 46.3 percent surge in the Northeast. They rose 17.4 percent in the West to 317,000, the most since July 2007.
A claim for unjust enrichment may be brought against a contractor or owner as an equitable claim to address unexecuted change orders. As the Court stated in Della Ratta v. Della Ratta, 927 So.2d 1055 (Fla. 4th DCA 2006), "to state a claim for unjust enrichment, a plaintiff must plead the following elements:1) the plaintiff has conferred a benefit on the defendant;2) the defendant has knowledge of the benefit;3) the defendant has accepted or retained the benefit conferred;and 4) the circumstances are such that it would be inequitable for the defendant to retain the benefit without paying fair value for it." Trenton H. Cotney Florida Bar Certified in Construction Law Glenn Rasmussen Fogarty & Hooker, P.A. 100 S. Ashley Dr., Suite 1300 Tampa, FL 33602 (813) 229-3333http://www.glennrasmussen.com
The elements necessary to state a cause of action for fraud in the inducement are 1) a false statement concerning a material fact, 2) knowledge by the person making the statement that the representation is false, 3) intent by the person making the statement that the representation will induce another to act upon it, and 4) reliance on the representation to the injury of the other party. Mettler, Inc. v. Ellen Tracy, Inc., 648 So.2d 253 (Fla. 2d DCA 1994). Trenton H. Cotney Florida Bar Certified in Construction Law Glenn Rasmussen Fogarty & Hooker, P.A. 100 S. Ashley Dr., Suite 1300 Tampa, FL 33602 (813) 229-3333 http://www.glennrasmussen.com
Butler v. Yusem, 44 So.3d 102 (Fla. 2010): "there are four elements to fraudulent misrepresentation: (1) a false statement concerning a material fact; (2) the representor's knowledge that the representation is false; (3) an intention that the representation induce another to act on it; and (4) consequent injury by the party acting in reliance on the representation."
Trenton H. Cotney Board Certified in Construction LawTrent Cotney, P.A.1207 N Franklin St, Ste 222Tampa, FL 33602(813) 579-3278www.trentcotney.com