Plaintiff accountants appealed the decision of the Superior Court of Los Angeles County (California), which denied its request to amend the complaint to add a cause of action for fraud to its breach of contract claims against defendant company. Defendant appealed the trial court’s correction of the jury’s damage award and an award for the tort of bad faith denial of contract.
California Business Lawyer & Corporate Lawyer, Inc. can explain CACI Breach of Fiduciary Duty
Overview
Plaintiff accountants filed a complaint against defendant company alleging breach of contract, bad faith denial of contract, and quantum meruit in connection with an unpaid bill for accounting services. After a jury verdict in plaintiffs’ favor, the trial court corrected the jury’s damage awards for compensatory and punitive damages on plaintiffs’ motion. Defendant appealed the trial court’s judgment, alleging that the trial court lacked jurisdiction to correct the damages and that the award of damages for the tort of bad faith denial of contract was improper. Plaintiff appealed the trial court’s refusal to permit an amendment of the complaint to add a cause of action for fraud. The court held that the trial court erred in correcting the judgment where there was no clerical error and the judgment conformed to the jury’s verdict. The court also determined that the award of punitive damages for the tort of bad faith denial of a contract was improper because there was no special relationship between the parties indicative of unequal bargaining positions. The court reversed the trial court’s judgment and remanded for a new trial on the limited issue of breach of contract damages.
Outcome
The court reversed the trial court’s judgment in favor of plaintiff accountants, holding that the trial court erred in correcting the jury’s award where there was no clerical error and that the award of tort damages for bad faith denial of contract was improper where there was no special relationship between the parties. The court remanded for a limited new trial on the issue of breach of contract damages.