Team Contractors, LLC v. Waypoint NOLA, LLC, No. 19-30704 (5th Cir. 2020)Annotate this Case
Waypoint, the project owner, entered into a construction contract with Team Contractors, the general contractor, and entered into an architectural contract with HCA. HCA then retained KLG as the project's engineer. Team filed suit and subsequently prevailed against the engineers and architects for negligence, but not against the owner for breach of contract. After a finding that the initial verdict had an irreconcilable conflict, a second trial was held just on the breach of contract claim. The jury then reached a verdict for the general contractor, and the owner appealed.
The Fifth Circuit vacated the district court's judgment and remanded for the district court to reinstate the original verdict. The court held that if the answers to written questions require jurors to apply the instructed law to their fact-findings, thereby fully explaining who prevails on all claims against a single defendant, and if relevant, the amount of any monetary award, that is sufficient for a Federal Rule of Civil Procedure 49(b) verdict. Though in this case the jurors were not given, as Rule 49(b) states, "forms for a general verdict" and also for answers to written questions, jurors applied their instructions on the law to their fact finding and found there had been no breach of contract. The court held that the result fully resolved the claim against Waypoint. The court stated that the general verdict is incomplete in Rule 49(b) terms, but it is sufficient. The court also held that Team waived any argument to have the verdict set aside. Finally, the court remanded for the district court to consider attorneys' fees.