J. Clancy, Inc. v. Khan Comfort, LLCAnnotate this Case
The Supreme Court reversed in part the decision of the circuit court concluding that J. Clancy, Inc.'s mechanic's liens placed against certain property were valid and unenforceable and rejecting J. Clancy's breach of contract and unjust enrichment claims, holding that the trial court erred in holding that a divisible implied-in-fact contract controlled the parties' express agreement.
J. Clancy, a construction company, sued Ghazanfar Khan and his company, Khan Comfort, LLC. J. Clancy sought enforcement of mechanic's liens it placed against the property and, in the alternative, brought claims for breach of contract and unjust enrichment. The circuit court concluded (1) the mechanic's liens were unenforceable because they were insufficiently itemized; (2) a divisible, implied-in-fact contract, rather than an express contract, governed the parties' relationship; and (3) J. Clancy breached the contract due to non-performance. The court then ordered J. Clancy to reimburse Khan Comfort for overpayments Khan Comfort made. The Supreme Court reversed in part and remanded the case, holding that the circuit court (1) erred in concluding that a divisible implied-in-fact contract controlled the parties' express agreement because a valid, express contract controlled the parties' obligations; and (2) erred in invalidating the mechanic's liens for inadequate itemization.