Bruneau v. Crescent City Cleaning Services Corp.
2016 La. App. LEXIS 2274, 209 So.3d 286, 16 La.App. 5 Cir. 17 (2016)
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Rule of Law:
To prevail on a breach of contract claim, a plaintiff must prove by a preponderance of the evidence not only that the defendant breached an obligation, but also that this specific breach was the legal cause of the plaintiff's damages.
Facts:
- In 2007, Charles Emile Bruneau, Jr. hired Crescent City Cleaning Services, Inc. based on a verbal agreement and a pamphlet advertising its employees as 'honest, hard-working individuals.'
- Bruneau provided Crescent City's owners, Elaine Hurst and Bridget Faucheux, with a key and alarm code, and instructed them not to bring 'one type of person' into his home.
- The key provided to Crescent City also unlocked an interior closet door, inside of which Bruneau kept a safe containing money and other valuables.
- Bruneau kept the combination to the safe inside a metal eyeglasses case in a bedroom dresser drawer.
- On April 29, 2010, Hurst and Faucheux brought Hurst's son, Gus, who had a criminal record, to assist with cleaning Bruneau's home.
- While at the home, Gus attempted to open the interior closet door where the safe was located but was stopped by Faucheux.
- On May 2, 2010, Bruneau's home was burglarized; the back door was kicked in and an envelope containing $8,500 and other documents was stolen from the safe.
- Other valuables, including jewelry, an antique pistol, and flatware, were left inside the safe.
Procedural Posture:
- Charles Emile Bruneau, Jr. filed a 'Petition for Damages and Breach of Contract' against Crescent City Cleaning Services, Inc., Elaine Hurst, and Bridget Faucheux in the First Parish Court for the Parish of Jefferson (a trial court).
- Crescent City filed a reconventional demand (counterclaim) against Bruneau for slander, defamation, and libel.
- After a bench trial, the trial court rendered a judgment in favor of Bruneau, finding that Crescent City breached its contract and that it was 'more likely than not' that Gus facilitated the burglary.
- The trial court awarded Bruneau $8,300 in damages for loss of property and dismissed Crescent City's counterclaim.
- Crescent City Cleaning Services, Inc., Elaine Hurst, and Bridget Faucheux (as Appellants) appealed the trial court's judgment to the Court of Appeal of Louisiana, Fifth Circuit (an intermediate appellate court).
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Issue:
Does a cleaning company's breach of an oral agreement not to bring individuals with a criminal history into a client's home make it liable for damages from a subsequent burglary when there is insufficient evidence to prove the individual caused or facilitated that burglary?
Opinions:
Majority - Marc E. Johnson
No. A defendant is not liable for damages resulting from a breach of contract unless the plaintiff proves by a preponderance of the evidence that the breach caused the damages. The court found that while Mr. Bruneau proved Crescent City breached its agreement by bringing Gus, an individual with a criminal history, into his home, he failed to prove the third essential element of a breach of contract claim: causation. The evidence presented was insufficient to establish that it was 'more likely than not' that Gus was involved in the burglary that occurred three days later. The facts that Gus had a criminal record and was present in the home prior to the burglary, while suspicious, did not meet the legal standard of proof required to link Crescent City's breach to Bruneau's financial loss.
Analysis:
This case underscores the critical importance of the causation element in breach of contract claims. It establishes that a proven breach of a contractual duty does not automatically result in liability for subsequent damages; the plaintiff bears the burden of directly linking the breach to the harm suffered. The court's decision illustrates that circumstantial evidence creating suspicion is not a substitute for evidence that proves causation by a preponderance of the evidence. This ruling serves as a precedent that in cases involving intervening criminal acts, a plaintiff must provide specific evidence connecting the defendant's breach to the criminal act itself, rather than relying on inferences drawn from the character or past actions of an individual associated with the defendant.
