Winning Breach of Contract Lawsuits: Proving Breach of Contract Duties

Introduction

Establishing a breach of contract is one of the most crucial elements in winning a breach of contract lawsuit. The success of such cases often hinges on the plaintiff’s ability to prove that the defendant failed to fulfill their contractual obligations. This proof is not just a technical requirement; it is the cornerstone of the case’s theory and significantly influences the strategy for proving damages and causation. Understanding how to effectively demonstrate a breach of contract duties can lead to favorable outcomes for the plaintiff. In this section on Winning Breach of Contract Lawsuits I guide you through key themes such as defining breach of duty, techniques for establishing a breach, proving materiality, and the critical role these elements play in connecting the breach to the plaintiff’s damages.

30:11 CONTRACT PERFORMANCE — BREACH OF CONTRACT DEFINED A breach of contract is the failure to perform a contractual promise when performance is due. (A material breach occurs when a party fails to (substantially perform) (or) (substantially comply with) the essential terms of a contract.) (A breach is not material if the other party received substantially what (he) (she) (it) contracted for. In determining whether a breach is material, you may consider the nature of the promised performance, the purpose of the contract, and whether any defects in performance have defeated the purpose of the contract.) (A material breach by one party excuses performance by the other party to the contract.)
Breach of Contract – Defined (Jury Instruction 30:11)

Understanding Breach of Contract Duties

A breach of contract occurs when one party fails to perform any of their contractual obligations without a legitimate legal excuse. This failure can relate to various types of duties, which are essential to understanding in the context of a lawsuit.

  • Express Duties: These are explicitly stated in the contract. When an express duty is breached, it is relatively straightforward to identify the non-performance since the contract explicitly defines the duty.
  • Implied Duties: These are not written into the contract but are understood to be part of the agreement, such as the duty of good faith and fair dealing.
  • Statutory Duties: Some duties are imposed by law, regardless of whether they are mentioned in the contract.

In litigation, your themes and theories of the case play a significant role in framing the breach. For instance, a theory based on non-performance focuses on the failure to meet contractual terms, while a theory of bad faith highlights the defendant’s intention behind the breach. Establishing which type of duty was breached and aligning it with the appropriate theory of the case is a critical first step.

Techniques for Establishing a Breach of Duty

Proving a breach of contract involves a systematic approach that includes gathering evidence, utilizing witnesses, and deploying effective discovery strategies.

  • Evidence Collection: The foundation of proving a breach is collecting comprehensive evidence. Key documents include the original contract, any amendments, communications between parties (emails, letters), and any relevant financial records. This documentation will reflect the backdrop on proof of whether the defendant’s actions or inactions constituted a breach.
  • Utilizing Witnesses: Witnesses, both expert and fact witnesses, play an essential role in corroborating the breach. Expert witnesses might explain the industry standards or interpret complex contract terms, while fact witnesses, such as employees or third parties involved in the contract or its fulfillment, can testify about the defendant’s failure to perform and surrounding circumstances.
  • Discovery Strategies: Effective discovery is vital in uncovering the evidence needed to prove or corroborate a breach. This can include depositions, where the opposing party is questioned under oath; interrogatories, which are written questions that must be answered; and requests for documents. Tailoring these strategies to target the breach specifics increases the likelihood of uncovering compelling evidence.

Establishing the Materiality of the Defendant’s Breach

Not all breaches are created equal. For a breach to be actionable, it must be material – that is, it must significantly affect the contract’s outcome or deprive the plaintiff of the benefit they expected to receive.

  • Defining Materiality: Materiality is a concept that assesses whether the breach had a significant impact on the contractual relationship. Courts typically consider factors such as the extent to which the breach affected the overall contract, whether the plaintiff received substantially what they bargained for, and whether the breach was intentional.
  • Proving Materiality: To prove materiality, it’s essential to demonstrate how the breach undermined the contract’s primary purpose. For instance, if a contractor fails to meet critical deadlines, thereby preventing the project’s timely completion, this could be argued as a material breach. Citing precedents and providing clear examples from the contract’s performance timeline, purpose, and expectations can strengthen this argument.

Integrating Breach of Duty into Case Themes

The breach of duty should be seamlessly integrated into the broader case themes. This alignment ensures that the argument for breach supports the overall narrative and resonates with the judge or jury.

  • Connection to Theories of the Case: Theories of the case provide the framework within which the breach is argued. For instance, a theory focusing on bad faith will incorporate the breach as evidence of the defendant’s intentional disregard for the contract’s terms. This theory then guides the narrative presented throughout the trial.
  • Strategic Considerations: Strategically, the breach of duty should be highlighted in opening statements, used to guide witness questioning, and emphasized in closing arguments. By consistently reinforcing the breach throughout the trial, it becomes a central theme that supports the plaintiff’s claims and damages sought.

Leading to Causation and Plaintiff’s Damages

Once the breach is established, the next critical step is proving that the breach caused the plaintiff’s damages. This transition is essential for securing compensation.

  • Transitioning from Breach to Causation: Establishing a breach sets the stage for proving that the breach directly caused harm to the plaintiff. This causal link must be clear and compelling, showing that but for the defendant’s breach, the plaintiff would not have suffered the damages they are now seeking.
  • Proving Damages: Demonstrating damages involves not only showing that harm occurred but also quantifying it. This can include lost profits, additional expenses incurred due to the breach, or the cost of rectifying the breach. Presenting detailed financial records and expert testimony is often necessary to substantiate these claims.

Conclusion

Successfully winning a breach of contract case requires more than just showing that a contract was breached; it involves proving that the breach was material, strategically integrating this proof into the case’s themes, and demonstrating a direct link between the breach and the plaintiff’s damages. Early and thorough preparation in these areas can significantly increase the likelihood of a favorable outcome. Whether through meticulous discovery, effective use of witnesses, or strategic trial presentations, establishing the breach of contract duties is a pivotal step toward winning the case.