Prime Trees and Landscaping Services D/B/A/ Mulch Matters v. Americon Services Company, Inc.
This breach-of-contract case involved Prime Tree and Landscaping Services (Mulch Matters) appealing a trial court's partial summary judgment and final judgment in favor of Americon Services Company. The dispute centered on a contract for 'select fill' dirt with specific plasticity index (PI) requirements for a construction project. Prime Tree contended the PI specifications were not part of the agreement and raised defenses of fraudulent inducement and lack of authority regarding the contract's terms. The Court of Appeals affirmed the trial court's decision, ruling that Mulch Matters' estimate had unambiguously incorporated Americon's Purchase Order, thus including the PI specifications in the contract. Additionally, the court upheld the jury's award of $30,500 in damages to Americon, finding sufficient evidence that the costs incurred to remedy the non-conforming dirt were reasonable and necessary.