Moore Custom Trailers v. Bryan J. Lynch (mem. dec.)
20A05-1611-SC-2520
Ind. Ct. App.Aug 31, 2017Background
- Lynch was hired by Moore Custom Trailers in May 2015 to manage/develop its service department; no written employment contract was completed.
- Lynch testified the parties agreed to an annual salary of $52,000 plus 20% of billed labor; a witness (his then-wife) corroborated this.
- Moore’s owner, McKibben, testified the deal was $52,000 plus a percentage of profitability and that the service center was not profitable.
- Lynch produced work-order printouts (Plaintiff’s Exhibits A & B) showing billed labor totals for the relevant period; the court totaled billed labor of $46,743.82.
- The small claims court found an oral agreement to pay Lynch 20% of billed labor, calculated 20% of the billed labor total ($9,348.76), and entered judgment capped at the small-claims limit of $6,000 in Lynch’s favor.
- Moore appealed arguing no enforceable oral contract, no meeting of the minds, and that the exhibits did not corroborate Lynch’s claimed entitlement to 20% of labor.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Existence of an enforceable contract for 20% of billed labor | Lynch: Parties agreed orally to $52,000 + 20% of billed labor; corroborated by witness and work orders | Moore: No meeting of the minds; terms were ambiguous and no written contract was produced | Court: Not clearly erroneous to find an oral agreement including 20% of billed labor (bench credibility finding upheld) |
| Admissibility/corroborative value of work-order printouts | Lynch: Exhibits show billed labor amounts that corroborate his claim and enable damage calculation | Moore: Exhibits do not prove entitlement to 20% and do not reflect payments to Lynch | Court: Exhibits sufficiently corroborated billed labor amounts; court used them to calculate damages |
| Proper construction of ambiguous terms | Lynch: Ambiguity should be construed against Moore, who was to draft the written contract | Moore: Ambiguity defeats enforceability; unclear essential terms | Court: Even if ambiguous, reasonable interpretation supports enforceability; ambiguity weighed against Moore in credibility assessment |
| Damages calculation and small-claims cap | Lynch: 20% of billed labor yields greater damages but limited by small-claims jurisdictional cap | Moore: Challenges underlying entitlement and calculation | Court: Accepted labor total and 20% calculation but entered judgment at $6,000 (jurisdictional cap) |
Key Cases Cited
- Conwell v. Gray Loon Outdoor Mktg. Grp., Inc., 906 N.E.2d 805 (Ind. 2009) (contracts require offer, acceptance, consideration, and reasonable certainty of essential terms)
- Eagle Aircraft, Inc. v. Trojnar, 983 N.E.2d 648 (Ind. Ct. App. 2013) (appellate review of bench trials: do not reweigh evidence; affirm unless clearly erroneous)
- Trinity Homes, LLC v. Fang, 848 N.E.2d 1065 (Ind. 2006) (substantive legal rules are reviewed de novo even in small-claims appeals)
- Yanoff v. Muncy, 688 N.E.2d 1259 (Ind. 1997) (findings control as to issues they cover; general judgment may be sustained on any legal theory supported by evidence)