AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The case involves a dispute between Advantage Drilling, LLC (Advantage), and Mayan Construction, Inc. (Mayan), concerning two subcontracts for drilling work on the Isleta Drain Project. Despite a history of conducting business without written contracts, Advantage requested written subcontracts for this project. Although the parties agreed on the price and services, they never finalized the written subcontracts. Advantage began work but stopped due to unresolved issues, leading to a series of proposals and rejections between the parties. Advantage filed a complaint for damages against Mayan, asserting various claims including breach of contract and unjust enrichment, after Mayan attempted to cancel a lien Advantage placed on the project (paras 2-9).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Appellant (Mayan Construction, Inc.): Argued that the district court erred in awarding contract damages without finding a breach of contract by Mayan, contended that insufficient evidence supported any breach, disputed the damages award based on unjust enrichment, and objected to the order for Mayan to reimburse Advantage for half of the construction materials' cost (para 1).
• Appellee (Advantage Drilling, LLC): Asserted claims for breach of contract, breach of a settlement agreement, judgment under lien statutes, breach of the covenant of good faith and fair dealing, judgment against the bond, and unjust enrichment or quantum meruit (para 2).

Legal Issues

• Whether the district court erred in awarding damages for breach of contract without a finding or conclusion that Mayan breached any contract.
• Whether the district court erred in basing the damages award on an unjust enrichment theory.
• Whether the district court erred in ordering Mayan to reimburse Advantage for half of the construction materials' cost and requiring joint action in disposing of the materials (para 1).

Disposition

• The Court of Appeals affirmed in part and reversed in part the district court's order. It upheld the award for reasonable costs incurred under the subcontracts but reversed the award for construction materials due to a lack of substantial evidence supporting the loss suffered by Advantage (paras 25-26).

Reasons

• Per JAMES J. WECHSLER, Judge (RODERICK T. KENNEDY, Chief Judge, and M. MONICA ZAMORA, Judge concurring):
  The court found substantial evidence supporting the district court's finding that Mayan and Advantage entered into subcontracts for drilling work on the project, based on the parties' conduct and tacit understanding, despite the lack of signed written agreements (paras 12-18).
  The court held that the district court erred in finding Mayan failed to mitigate damages for the construction materials purchased by Advantage. The award of $19,870.50 for construction materials was not supported by substantial evidence, as there was no evidence that the materials retained by Advantage had diminished in value or that the awarded amount reflected the actual reasonable loss suffered by Advantage (paras 19-24).