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Maine Supreme Judicial Court - 711 A.2d 141
Tags: Contracts, Conditions
tl;dr:
Defendant city hired Plaintiff to do snow plowing work and road sanding. The contract for the work was contingent upon voter approval of a specific road work budget, but this budget failed and Defendant wanted to pay Plaintiff less.Video Summary
Case Summary
In the 1998 case Irving v. Town of Clinton, a snowplow operator sued a town for allegedly breaking a contract regarding road plowing. The snowplow operator claimed they signed an agreement for $107,723.96 with the town's selectmen but the town lowered the amount to $99,999 after a vote. The town claimed the contract depended on voter approval, which the operator never accepted.
The trial court sided with the town, and the operator appealed. The court ultimately agreed with the town, stating the contract was never properly formed since it required voter approval—an express condition precedent that didn't happen. The court declared this contract as only an offer by the operator, which voters could accept or reject. Since voters altered the plowing amount, the court determined they rejected the original offer, and the snowplow operator didn't accept the new counteroffer.
This case demonstrates how courts apply state law and contract principles while taking into account explicit and implied terms and external factors. It also displays how courts balance fairness and justice with the independence and discretion of involved parties. Furthermore, this case emphasizes the significance of good faith and fair dealings in municipal transactions.
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Kenneth Irving, Jr. appealed a summary judgment in favor of the Town of Clinton on his breach of contract claim. The majority opinion affirmed the judgment, stating that the contract was contingent upon voter approval, which did not occur. The lower court did not err in entering the summary judgment as the selectmen did not have the authority to enter into a contract on behalf of the municipality, and even if they did, the contract was contingent upon voter approval, which did not happen.
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