RMR Equipment Rental, Inc. v. Residential Fund 1347, LLC
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Residential Fund entered a contract with RMR for RMR to supply Residential Funds' mobile home park with drinking water beyond what the wells could produce. The trial court subsequently found that the park breached the contract in 2015 but limited RMR's damages to three months, reasoning that the contract was terminable at will. RMR requested damages be calculated from breach to the date of trial, which was about four years.
The Court of Appeal concluded that the trial court erred by awarding damages for three months only where the contract between the parties was a requirements contract that was not terminable at will. In this case, the contract had an express termination clause that the court must respect, and thus the trial court should have awarded damages for roughly four years. Accordingly, the court remanded for a calculation of an award based on this interval.
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