SERVICES LLC v. NEW BRIDGE PARTNERS LLC (2025)

This case involves cross claims for breach of a contract between New Bridge Partners, LLC (New Bridge) and CDW Services (CDW). The jury found New Bridge did not breach any contractual obligations owed to CDW, but CDW breached contractual obligations owed to New Bridge. The jury was instructed, “Please provide the amount of money that would fairly and reasonably compensate [New Bridge] for any damages it incurred resulting from the breach by CDW.” The jury awarded $290,000.

After making those determinations, the jury was instructed to quantify the percentage of fault of CDW, New Bridge, three named individuals, and “others,” which the jury did, assigning 29% fault to New Bridge. The trial court rendered judgment in favor of New Bridge for $290,000, reducing the award by 38%, the percentage of fault allotted to CDW. Finding the verdict ambiguous, the court of appeal vacated the trial court's judgment and remanded for a new trial. C.D.W. Services, LLC v. New Bridge Partners, LLC, 2024-0081 (La. App. 4 Cir. 11/12/24), ––– So. 3d –––– (2024 WL 5086306).

We find no ambiguity in either the jury determination that CDW breached the contract or the award of $290,000 to fairly and reasonably compensate New Bridge. An obligor is liable for the damages caused by its failure to perform its contractual obligations. La. Civ. Code art. 1994. CDW and New Bridge were the only parties to the contract. CDW was the only party who breached the contract. The trial court erred in instructing the jury relative to comparative fault, leading the jury to err by apportioning fault. The trial court again erred by reducing the damages. However, we find the jury's intentions sufficiently clear relative to the breach of contract and damages caused by the breach to conclude that the legal errors did not interdict the fact-finding process. Neither remand for new trial nor de novo review is necessary. The errors are properly remedied by amending the trial court judgment to reflect the jury's answer to the special interrogatory expressly stating the amount of damages that will compensate New Bridge for CDW's breach of contract. See La. Code Civ. P. art. 1916.

The writ is granted and the judgment of the court of appeal is reversed. The trial court judgment is amended to render judgment in favor of New Bridge Partners, LLC, and against CDW Services, LLC, in the amount of $290,000. As amended, the trial court judgment is affirmed.

WRIT GRANTED; COURT OF APPEAL JUDGMENT REVERSED; TRIAL COURT JUDGMENT AMENDED AND AFFIRMED.

PER CURIAM