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Thomas v. Jim Walter Homes, Inc.

Citations: 282 S.C. 267; 317 S.E.2d 768; 1984 S.C. App. LEXIS 499Docket: 0204

Court: Court of Appeals of South Carolina; June 22, 1984; South Carolina; State Appellate Court

Narrative Opinion Summary

In this case, the plaintiff sued the defendant corporation for breach of contract concerning the construction of a house. Initially, the trial court allowed the plaintiff to amend the complaint to add a claim for breach of the implied warranty of habitability, which the jury found in the plaintiff's favor, awarding damages. The appellate court reviewed three primary issues: the defendant's responsibility for septic tank malfunctions, the propriety of the amended complaint, and the sufficiency of evidence supporting the damages awarded. The court affirmed that the defendant was responsible for construction issues leading to septic problems due to the improper elevation of the house. It also upheld the amendment of pleadings, noting the defendant's failure to object. However, the court found insufficient evidence for the awarded damages, as the plaintiff failed to substantiate costs beyond $2,000. Consequently, the appellate court affirmed the liability verdict but reversed the damage award, remanding the case for a new trial solely on the issue of damages. The decision was concurred by all judges, with one providing a separate concurring opinion.

Legal Issues Addressed

Amendment of Pleadings

Application: The trial court permitted the addition of a breach of implied warranty of habitability claim during the trial, which was upheld on appeal due to lack of objection from the appellant.

Reasoning: The appellate court affirmed the trial judge's ruling that Jim Walter was contractually responsible for septic issues and upheld the amendment of pleadings concerning the implied warranty claim, as Jim Walter did not object at trial.

Breach of Implied Warranty of Habitability

Application: The jury found in favor of the plaintiff on the breach of implied warranty of habitability due to the improper construction height of the house affecting sewage flow.

Reasoning: The trial court allowed Thomas to amend her complaint to include a cause of action for breach of implied warranty of habitability, which the jury subsequently found in her favor.

Contractual Responsibility for Construction Issues

Application: The defendant was held responsible for septic tank issues caused by construction decisions made by the defendant, specifically the insufficient elevation of the house.

Reasoning: Key uncontested facts include that Thomas owned the lot, was required by DHEC to install the septic tank, and the house was constructed at a height insufficient to ensure proper sewage flow due to site selection by Jim Walter.

Sufficiency of Evidence for Damages

Application: The appellate court found insufficient evidence to support the original damage award, necessitating a new trial on damages.

Reasoning: However, the court found insufficient evidence to support the remitted damages of $6,000, as no testimony was provided regarding the costs associated with delays or repairs, with clear proof of damages only amounting to $2,000.