## Facts

- A bride contracted with a hotel to host and cater a wedding reception on a specified date; the written agreement referred generally to “function space” and allowed reassignment to accommodate hotel operations.
- The parties’ communications consistently identified a particular ballroom as the planned reception location.
- The contract provided that if the hotel canceled or could not provide the requested space, it would work with the group to arrange comparable alternative space in the vicinity and provide transportation if needed.
- Shortly before the wedding, municipal authorities closed the identified ballroom for safety violations.
- The hotel moved the reception to the hotel lobby, which was materially inferior (smaller, no ocean view, and not separable from general hotel traffic).
- The couple learned of the closure and relocation on the morning of the wedding; the reception proceeded in the lobby with catering and setup of the couple’s vendors.
- The couple sued for breach of contract and intentional infliction of emotional distress (IIED). A jury found for the couple on both claims, awarded contract damages to each spouse, and awarded additional damages for IIED.

## Issues

1. Whether the hotel breached the event contract by relocating the reception from the identified ballroom to the lobby in light of the “function space” and “hotel’s cancellation/alternative space” provisions.
2. Whether the jury’s contract-damages awards were supported by competent, substantial evidence or improperly included duplicative amounts (including a separate ballroom rental component).
3. Whether the hotel’s conduct in delaying notice and relocating the event satisfied Florida’s “extreme and outrageous” threshold for IIED.

## Decision

- Affirmed the finding of breach of contract.
- Reversed in part as to contract damages, holding that the evidence did not support the full amount awarded where the plaintiffs’ theory duplicated charges already included in the contract price.
- Reversed the IIED judgment and vacated the IIED damages because the hotel’s conduct did not meet Florida’s legal standard for “outrageous” conduct.
- Remanded for further proceedings consistent with the appellate ruling.

## Legal Principles

- Contract interpretation may consider course of dealing and communications to determine the parties’ understanding of generic venue terms such as “function space.”
- When a contract requires “comparable” substitute space if the specified space becomes unavailable, providing a materially inferior substitute may constitute breach, even if the contract permits reassignment of space.
- Contract damages must reflect provable expectation loss and cannot award a windfall or double recovery for amounts already included in the contract price.
- Under Florida law, IIED requires conduct so extreme and outrageous as to be beyond all bounds of decency; service failures and contract breaches, even in emotionally significant settings, generally do not satisfy that threshold absent especially egregious behavior.

## Conclusion

The appellate court upheld the jury’s breach determination based on the parties’ shared understanding and the contract’s comparable-space obligation, but limited contract damages to non-duplicative losses and rejected IIED because the hotel’s conduct, though distressing, was not legally outrageous.


Deauville Hotel Mgmt., LLC v. Ward, 219 So. 3d 949 (Fla. 3d DCA 2017)