Ryffel Family Partnership Ltd. v. Alpine Country Construction, Inc.
2016 MT 350
| Mont. | 2016Background
- Ryffel Family Partnership (Texas-based) engaged Alpine Country Construction to perform logging, road work, and related services on Montana property in 2007; two oral agreements are at issue (January 2007 and September 2007).
- Parties disputed payment terms: Alpine billed hourly for some work; later a September meeting produced competing recollections—Alpine says proceeds-split arrangement with offsets to Alpine; Ryffel says he paid $45,000 (enclosed check and letter) for a line machine and expected proceeds split and cessation of further cutting.
- Alpine continued work, issued invoices, applied log-sale credits, and after accounting asserted Ryffel Partnership owed roughly $50,348.18 (Alpine’s figure); Ryffel’s expert calculated Alpine owed Ryffel $41,105.88 from log sales.
- Ryffel sued (or was sued) and a jury found Ryffel breached both oral contracts, awarded Alpine zero contract damages, but awarded $50,348.18 for unjust enrichment and $25,000 for breach of the covenant of good faith and fair dealing.
- The district court, via M.R. Civ. P. 59 amendment, reassigned the $50,348.18 unjust-enrichment award to the breach-of-contract finding (to correct legal inconsistency) and vacated the $25,000 good-faith award as unsupported and duplicative; Alpine’s motion for pre-judgment interest was denied (by court inaction) and later deemed denied.
- Ryffel appealed arguing insufficient evidence for breach of the September agreement and sought a new trial for an allegedly inconsistent verdict; Alpine cross-appealed the denial of pre-judgment interest. The Montana Supreme Court affirmed the district court on all points.
Issues
| Issue | Plaintiff's Argument (Ryffel) | Defendant's Argument (Alpine) | Held |
|---|---|---|---|
| 1) Was there substantial evidence to support breach of the Sept. 2007 (second) oral agreement? | Ryffel: Insufficient evidence; contends the $45,000 check and letter constituted satisfaction/waiver; terms unclear. | Alpine: Testimony and accounting supported existence and breach of an oral agreement; credits and invoices show performance and damage. | Held: Sufficient evidence existed; jury could credit Alpine’s version and reject waiver/accord defenses. |
| 2) Did the jury render an inconsistent or illegal verdict requiring a new trial? | Ryffel: Verdict finding breach and also unjust enrichment is legally inconsistent; new trial required. | Alpine: Special verdict offered both theories; district court can correct inconsistency by reallocating damages to contract breach. | Held: No abuse of discretion; district court properly amended verdict to assign unjust-enrichment damages to breach-of-contract and vacated duplicative good-faith award. |
| 3) Was pre-judgment interest under §27-1-211, MCA, owed to Alpine? | Alpine: Recovery was calculable; prejudgment interest should run. | Ryffel: Amount and terms were disputed and not vested until verdict. | Held: Denial affirmed; amount was not certain or vested pre-verdict due to disputed oral terms and accounting. |
| 4) Was the $25,000 award for breach of the covenant of good faith and fair dealing supportable? | Ryffel: No evidence of additional damages; award is impermissible double recovery. | Alpine: Jury awarded it as additional damages. | Held: Vacated by district court and affirmed — unsupported and would duplicate recovery. |
Key Cases Cited
- Keil v. Glacier Park, Inc., 188 Mont. 455, 614 P.2d 502 (Mont. 1980) (elements required for enforceable oral contract)
- Maxted v. Barrett, 198 Mont. 81, 643 P.2d 1161 (Mont. 1982) (unjust enrichment unavailable where a legal contract exists)
- Rudeck v. Wright, 218 Mont. 41, 709 P.2d 621 (Mont. 1985) (new trial appropriate when jury verdicts are totally inconsistent with law)
- Abernathy v. Eline Oil Field Servs., Inc., 200 Mont. 205, 650 P.2d 772 (Mont. 1982) (conflicting jury findings from same evidence can warrant new trial)
- Northern Montana Hosp. v. Knight, 248 Mont. 310, 811 P.2d 1276 (Mont. 1991) (prejudgment interest inappropriate when damages were not certain or vested until verdict)
- Carriger v. Ballenger, 192 Mont. 479, 628 P.2d 1106 (Mont. 1981) (no interest until a fixed amount of damages is determined)