Inman v. Clyde Hall Drilling Co.
369 P.2d 498 (1962)
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Rule of Law:
A contractual provision requiring an employee to give written notice of a claim within a specified period as a condition precedent to recovery is enforceable and not contrary to public policy, unless there is clear evidence that one party unconscionably took advantage of the other's economic necessities or that there was a substantial inequality in bargaining power.
Facts:
- On November 16, 1959, Inman entered into a written employment contract with the Clyde Hall Drilling Company to work as a derrickman.
- The contract included a clause requiring Inman to give the Company written notice of any claim within 30 days of the claim arising.
- This clause explicitly stated that compliance was a 'condition precedent to any recovery' and that no lawsuit could be filed until six months after providing such notice.
- Inman acknowledged in a deposition that he had read the contract, discussed it with a company representative, and was familiar with its terms when he signed it.
- Clyde Hall Drilling Company terminated Inman's employment on March 24, 1960.
- Inman did not provide a separate written notice of his claim to the company after his termination.
Procedural Posture:
- On April 5, 1960, Inman (plaintiff) filed a lawsuit against the Clyde Hall Drilling Company (defendant) in the trial court for breach of an employment contract.
- The Company filed an answer denying it breached the contract.
- The Company later filed a motion for summary judgment, arguing that Inman's failure to provide written notice of his claim as required by the contract barred his lawsuit.
- The trial court granted the Company's motion for summary judgment and entered a final judgment in its favor.
- Inman (appellant) appealed the trial court's grant of summary judgment to this court.
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Issue:
Does a provision in an employment contract requiring an employee to give written notice of a claim within 30 days as a condition precedent to recovery violate public policy and is it therefore unenforceable?
Opinions:
Majority - Dimond, J.
No. A contractual provision making written notice of a claim a condition precedent to recovery does not violate public policy where there is no evidence of unfairness or unequal bargaining power. The court's role is to enforce contracts freely made by competent parties, and it will only refuse to do so on public policy grounds if there is clear evidence of unconscionability. In this case, there was no indication that the terms were unfairly imposed upon Inman or that the Company took advantage of him; he admitted he read and understood the contract. The court further held that filing a lawsuit does not satisfy a contractual requirement for pre-suit notice, as doing so would render the specific contract language meaningless. Finally, the company's alleged breach of contract by firing Inman did not excuse him from his obligation to perform the condition precedent required to bring a suit for damages.
Analysis:
This decision strongly reinforces the principle of freedom of contract, setting a high standard for invalidating contractual provisions on public policy grounds. It establishes that procedural requirements, such as notice clauses, will be strictly enforced if they are clearly stated and not the product of unconscionable conduct. The case clarifies that making notice a 'condition precedent' shifts the burden of pleading and proof to the plaintiff, distinguishing it from an affirmative defense the defendant must raise. This ruling makes it more difficult for parties to escape contractual obligations they later find burdensome, requiring them to produce concrete evidence of procedural or substantive unconscionability to have a term voided.
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