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Lamb v. Crayton
5:15-cv-00241
W.D. Ky.
May 15, 2017
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Background

  • In Jan 2013 Lamb and Crayton formed an oral agreement: Lamb wired $56,000 to fund purchase of two EMD diesel engines; proceeds (after repaying Lamb) would be split equally.
  • When the engines failed to sell as a package, the parties orally agreed to "part out" the engines and sell components, maintaining the same repayment-and-split arrangement.
  • Crayton sold approximately $61,300 of parts, incurred roughly $11,336 in advertising/labor, and estimates remaining parts worth ~$36,440; none of the proceeds were paid to Lamb and revenue went into Crayton Diesel’s general account.
  • Lamb sued for breach of contract (or unjust enrichment, alternatively) and fraudulent inducement, seeking $75,680 total; discovery closed and Lamb moved for summary judgment.
  • The primary factual dispute is timing: Lamb contends he was to be repaid as each part sold (rolling payments); Crayton testifies no timing was agreed and he intended to repay after selling higher-value components.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Existence/terms of an oral contract Lamb: a binding oral contract existed requiring rolling repayment as parts were sold Crayton: contract existed but timing of repayment was not agreed Court: contract existed but timing is disputed; jury must resolve terms
Breach of contract (timing) Lamb: failure to make rolling payments is breach Crayton: no agreed timing, so no breach as a matter of law Court: genuine dispute of material fact precludes summary judgment for Lamb
Unjust enrichment (alternative) Lamb: alternatively entitled to restitution if no enforceable contract Crayton: (implicit) contract governs remedy Court: unjust enrichment unavailable because an express contract covers the subject matter
Fraudulent inducement Lamb: Crayton knowingly misrepresented repayment timing to induce investment Crayton: denies intent/falsity; disputes the alleged representation Court: fraud claim overlaps with contract claim and is barred by the economic loss doctrine; summary judgment denied on that theory too

Key Cases Cited

  • Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard)
  • Laster v. City of Kalamazoo, 746 F.3d 714 (6th Cir. 2014) (no credibility determinations on summary judgment)
  • Frear v. P.T.A. Indus., Inc., 103 S.W.3d 99 (Ky. 2003) (oral contracts binding)
  • Equitania Ins. Co. v. Slone & Garrett, P.S.C., 191 S.W.3d 552 (Ky. 2006) (contract interpretation is a question of law absent factual dispute)
  • United Parcel Serv. Co. v. Rickert, 996 S.W.2d 464 (Ky. 1999) (elements of fraud)
  • Derby City Capital, LLC v. Trinity HR Servs., 949 F. Supp. 2d 712 (W.D. Ky. 2013) (economic loss doctrine bars contract-related fraud claims)
  • Westlake Vinyls, Inc. v. Goodrich Corp., 518 F. Supp. 2d 955 (W.D. Ky. 2007) (application of economic loss doctrine)
Read the full case

Case Details

Case Name: Lamb v. Crayton
Court Name: District Court, W.D. Kentucky
Date Published: May 15, 2017
Docket Number: 5:15-cv-00241
Court Abbreviation: W.D. Ky.