Stephan v. Waldron Electric Heating & Cooling LLC
100 A.3d 660
| Pa. Super. Ct. | 2014Background
- Stephan sued Waldron for alleged extreme overcharging for a minor electrical repair in a condominium unit.
- A magisterial district court awarded Stephan $1,413.00 total; Waldron appealed to the Court of Common Pleas.
- Stephan testified that Waldron’s electrician obtained his agreement to a price before work and that pricing was disclosed and signed after completion of the work.
- A trial/arbitration history culminated in an arbitration award favoring Stephan ($900), which Waldron appealed; a subsequent bench trial awarded Stephan $1,000.
- On appeal, the Superior Court vacated the judgment for Stephan, finding an enforceable contract and that Waldron’s charges were subject to contract terms and meaningful consideration.
- The court concluded Stephan and Waldron entered into an enforceable contract for the electrical repair, with Stephan liable for $1,469.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Enforceability of the contract | Stephan; contract existed and pricing was enforceable. | Waldron; contract terms were indefinite or unenforceable. | Contract enforceable; judgment vacated. |
| Adequacy of contract terms and consideration | Stephan agreed to price terms disclosed and signed; consideration present. | Waldron; terms unclear or added post hoc. | Terms sufficiently definite; contract valid and enforceable. |
| Credibility determinations in a non-jury trial | Stephan’s credibility supported the verdict. | Trial court’s credibility determinations should be respected. | Appellate review deferential; contract finding upheld despite credibility discussion in the trial court. |
| Appropriate measure of damages under contract | Damages consistent with agreed pricing; final bill aligns with contract price. | Overcharge beyond what was agreed or implied by contract. | Final amount consistent with contract and partial performance; judgment vacated in favor of Waldron. |
Key Cases Cited
- Lachat v. Hinchcliffe, 769 A.2d 481 (Pa. Super. 2001) (abuse of discretion standard; evidence sufficiency on appeal)
- Wyatt, Inc. v. Citizens Bank of Pennsylvania, 976 A.2d 557 (Pa. Super. 2009) (appellate review of non-jury trial; findings of fact reviewed for support)
- Humberston v. Chevron U.S.A., Inc., 75 A.3d 504 (Pa. Super. 2013) (contract interpretation; plain meaning of unambiguous terms)
- RegScan, Inc. v. Con-Way Transp. Services, Inc., 875 A.2d 332 (Pa. Super. 2005) (implied contract; consideration and reasonable value concepts)
- Cameron v. Eynon, 332 Pa. 529 (1939) (implied contract doctrine; consideration inferred from conduct)
- Home Protection Building & Loan Ass'n v. Irvine, 143 Pa. Super. 96 (1941) (implied promises to pay for services; payment inference principles)
- First Home Sav. Bank, FSB v. Nernberg, 436 Pa. Super. 377 (1994) (bilateral vs unilateral contracts; mutuality of obligation discussion)