Eckles v. Sharman
Nature of the Case
This was an appeal from a breach of contract action.
Facts
Sharman (D) had a coaching contract with the Los Angeles Stars. The contract included a provision for a pension and gave Sharman an option to purchase a percentage of the team. No specifics were ever reached regarding the option and the pension plan.
The team was sold to Mountain States Sports. Mountain States did not have an obligation to assume the Sharman contract unless he agreed to move with the team. Sharman did move to Utah and won the ABA championship in 1971. He resigned as coach of the Stars and contracted to coach the Los Angeles Lakers.
Mountain States declared bankruptcy and Eckles (P), the trustee, sued Sharman and the Lakers for breach of contract and for tortious inducement of breach of contract. Sharman claimed that the Stars contract was invalid because of the lack of agreement on the pension and option clauses. A directed verdict was given to Eckles on the grounds that those provisions were not material and did not invalidate the contract. Both defendants appealed.
Issues
- Is the materiality of a contract term a question of fact or of law?
- Can a question of fact be subject to a directed verdict?
Holding and Rule of Law
- The materiality of a contract term is a question of fact.
- A question of fact cannot be subject to a directed verdict.
The jury could have found that Sharman would not have intended to be bound if the pension and option provisions were not agreed upon. The jury should have determined whether the parties intended the contract to be enforceable in the absence of agreements on these unresolved provisions. A verdict may not be directed unless all the evidence points one way and is susceptible of no reasonable inferences which sustain the position of the party against whom the motion is made.
Disposition
Reversed and remanded.