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American Structural Systems, Inc. v. R.B. Gay Construction Co.

Citations: 619 So. 2d 366; 1993 Fla. App. LEXIS 5665; 1993 WL 169179Docket: No. 92-1114

Court: District Court of Appeal of Florida; May 21, 1993; Florida; State Appellate Court

Narrative Opinion Summary

The case involves a contractual dispute between a construction company and its subcontractor over a church construction project. Initially, the subcontractor was tasked with providing structural and miscellaneous metals. However, after the primary contractor decided to purchase steel directly, the subcontract's price was reduced. The primary contractor accused the subcontractor of breaching the contract by failing to supply a metal deck, while the subcontractor argued that it was not obligated to provide it and sought the remaining balance of the contract. In a non-jury trial, the court sided with the primary contractor, awarding damages for breach of contract. The subcontractor appealed, contesting both the obligation to supply the deck and the damage calculation. The appellate court affirmed the trial court's interpretation that the deck was required under the contract but found the damage calculation incorrect. It ruled that damages should be based on the difference between the contract price and the reasonable cost to complete the work. Consequently, the appellate court reversed the damage award and remanded the case for a recalculated amount in accordance with its clarification. The decision was concurred by Judges Allen and Wolf.

Legal Issues Addressed

Breach of Contract Requirements

Application: The court determined that the subcontractor was required to supply a metal deck as part of their contractual obligations.

Reasoning: The appellate court upheld the trial court's finding that the contract required the metal deck.

Calculation of Damages for Breach of Contract

Application: The appellate court found an error in the trial court's calculation of damages, ruling that damages should reflect the difference between the contract price and the reasonable cost to complete the work.

Reasoning: The court clarified that damages for breach should reflect the difference between the contract price and the reasonable cost to complete the work, not the total cost incurred by Gay.

Modification of Contract Obligations

Application: The contract amount was adjusted when the primary contractor opted to purchase materials directly, affecting the subcontractor's obligations.

Reasoning: After Gay opted to purchase steel directly, the subcontract amount was reduced.