Thursday, December 26, 2013

Brinderson-Newberg Joint Venture v. Pacific Erectors, Inc. case brief

Brinderson-Newberg Joint Venture v. Pacific Erectors, Inc. case brief summary
971 F.2d 272 (1992)

CASE SYNOPSIS
Appellant general contractor sought review from a judgment of the United States District Court for the Central District of California, which denied appellant's motions for a directed verdict and judgment notwithstanding the verdict in a case stemming from a contract dispute with appellees, a subcontractor and a bonding company. Appellees cross-appealed the district court's grant of summary judgment on fraud and misrepresentation claims.

CASE FACTS
Appellant general contractor challenged the denial of their motions for a directed verdict and judgment notwithstanding the verdict in a case involving a contract dispute with appellees a subcontractor and a bonding company. Appellees cross-appealed on fraud and misrepresentation claims. The primary issue for the court was the admission of parol evidence over the objections of appellant.

DISCUSSION

  • The court found that appellees' proffered interpretation stretched the contractual language beyond reasonable limits and violated most applicable rules of contract construction. 
  • Therefore, the district court erred in allowing the jury to hear parol evidence supporting appellees' proffered interpretation. 
  • Further, California held parties responsible for signing integrated contracts and allowed parol evidence of fraud only to the extent it did not contradict the integrated contract. 
  • Appellees' parol evidence contradicted the plain language of the contract. 
  • Thus, appellees' signing of the contract precluded a fraud claim based on the alleged promise to interpret the contact in a way that contradicted the plain language. 
  • The court reversed and remanded the fraud verdict and affirmed summary judgment.

CONCLUSION
The court reversed and affirmed in part in favor of appellant general contractor and against appellees, a subcontractor and a bonding company, in a case stemming from a contract dispute, fraud, and misrepresentation claims. The court held that the district court erred in allowing the jury to hear parol evidence supporting appellees' proffered interpretation because it contradicted the plain language of the contract that precluded a fraud claim.

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