The elements of a breach of contract claim are well known to many individuals and business owners. These elements are as follows:
1) existence of a valid contract;
2) breach of that contract; and
3) damages as a result of that breach.
A traditional defense to a breach of contract claim is that the breach was a “minor” breach and not a “material breach”. A “material breach” goes to the heart of a contract, whereas a minor breach is much less severe. Generally, a minor breach is actionable, however, a plaintiff would not receive as much of a damage award. The caliber of breach was never an element of a breach of contract claim until Florida recently altered this through several cases that came before the court.
In 2000, the Florida district court injected the materiality requirement into the rational for its case holding without explanation (Abbott Labs v. GE Capital, 765 So. 2d 737, 740 (Fla. 5th DCA 2000). Many cases followed with references to the Abbot Labs case. Further, in June of 2013, another court announced that the elements of a breach of contract claim were “(1) a valid contract, (2) a material breach, and (3) damages” (Havens v. Coast Florida, P.A., 117 So. 3d 1179 (Fla. 2d DCA 2013)). Materiality requires proof that the breach goes “to the essence of the contract.” No other state requires such materiality for a party to recover from a breach of contract claim.
Such Florida case law created a fundamental problem in pursuing breach of contract claims, however, the requirement was not coded by statute. Therefore, each court must still determine the materiality requirement on its own based on the facts and circumstances of each particular case.
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