## Facts

- On November 16, 1959, Roy D. Inman (plaintiff) signed a written employment contract with Clyde Hall Drilling Company (defendant) for work as an oilfield employee.
- The contract included a notice-of-claim clause covering employment-related claims other than workers’ compensation.
- The clause required the employee to provide the company written notice of any claim within 30 days after the claim arose, stating the relevant facts and the basis of the claim.
- The contract stated that giving this written notice was a condition precedent to any recovery by the employee.
- Inman’s employment ended when he was terminated on March 24, 1960.
- Inman did not provide the company the written notice described in the contract within 30 days after his termination.
- On April 14, 1960, Inman served a complaint on Clyde Hall Drilling Company alleging breach of the employment contract and seeking damages.
- The trial court entered judgment for the company on the ground that Inman’s failure to provide the required written notice barred recovery.
- Inman appealed to the Alaska Supreme Court.

## Issues

1. Is an employment-contract provision requiring an employee to give the employer written notice of claim within 30 days, as a condition precedent to recovery, enforceable rather than void as against public policy?
2. Can service of a breach-of-contract complaint substitute for the contractually required written notice of claim?

## Decision

- The Alaska Supreme Court affirmed judgment for Clyde Hall Drilling Company.
- The court held that the written notice-of-claim requirement, expressly made a condition precedent to recovery, was enforceable on this record.
- The court rejected the argument that the complaint served on April 14, 1960 satisfied the contract’s notice requirement, particularly where no contractual notice was given within the specified 30-day period.
- Because Inman did not satisfy the condition precedent, his breach-of-contract claim was barred.

## Legal Principles

- Courts generally enforce agreements made by competent parties unless a constitutional or statutory prohibition applies or enforcement would be unfair under the circumstances shown.
- Parties may create conditions precedent to suit or recovery by contract, including requiring timely written notice of claims.
- A contractual notice-of-claim requirement serves legitimate functions such as enabling prompt investigation, allowing early adjustment or settlement, and reducing the risk of stale or unsupported demands.
- When a contract makes timely written notice a condition precedent, the claimant must prove compliance (or a legally recognized excuse) to recover.
- Filing or serving a lawsuit is not the same as providing the specific contractual notice of claim, especially when the pleading is served after the time for notice has expired.

## Conclusion

Inman held that an employee who signed an employment contract requiring written notice of any claim within 30 days—and stating that such notice was a condition precedent to recovery—could not proceed on a breach-of-contract claim when he failed to provide that notice and instead served a complaint after termination. The Alaska Supreme Court enforced the notice condition and affirmed judgment for the employer.


Inman v. Clyde Hall Drilling Co., 369 P.2d 498 (1962)