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Bordelon v. Comeaux Furniture & Appliance, Inc.

Citations: 705 So. 2d 740; 1998 La. LEXIS 25; 1998 WL 63079Docket: No. 97-C-2864

Court: Supreme Court of Louisiana; February 12, 1998; Louisiana; State Supreme Court

Narrative Opinion Summary

This case involves a contract dispute between a cleaning service provider and a furniture and appliance company regarding compensation for carpet cleaning services rendered. The plaintiff, a cleaning service operator, initially performed a small-scale cleaning for a fixed price, which was paid by the defendant. Subsequently, the defendant requested a full-scale cleaning without a prior agreed price, leading to a billing dispute when the plaintiff invoiced the defendant $3,630.64 based on square-foot pricing, a customary industry practice. The trial court ruled in favor of the defendant, awarding only $1,440.00 based on a man-hour rate, and the appellate court upheld this decision. On further appeal, the higher court found that the lower courts erred by not applying the industry-standard pricing method, thereby failing to provide the plaintiff with reasonable compensation and profit. The court emphasized that contracts can exist without a predetermined price by implying a reasonable sum based on costs and industry standards. The judgment was reversed, awarding the plaintiff the full invoiced amount and assessing costs against the defendant, as the defendant did not challenge the accuracy of the measurements or the invoiced amount.

Legal Issues Addressed

Customary Pricing Practices in Service Contracts

Application: The court concluded that industry-standard square-foot pricing should have been applied instead of a man-hour rate, as charging by the hour is not customary in the carpet cleaning industry.

Reasoning: The court concluded that the trial and appellate courts erred by applying a man-hour pricing model instead of the industry-standard square-foot pricing for carpet cleaning. Testimonies indicated that charging by the hour is not customary in the industry.

Formation of Contracts without Agreed Price

Application: The court determined that the lack of an agreed price does not invalidate the contract, as a reasonable sum is implied based on actual costs and reasonable profits.

Reasoning: The higher court referenced precedent establishing that lack of an agreed price does not invalidate a contract, as a reasonable sum is implied. This includes actual costs and reasonable profits.

Remedy and Damages in Contract Disputes

Application: The court awarded the plaintiff the full amount invoiced, $3,630.64, as a fair compensation for services rendered, reflecting industry standards and avoiding unjust enrichment of the defendant.

Reasoning: Consequently, the court reversed the appellate judgment, awarding the plaintiff $3,630.64 and assessing all costs against the defendant.