Facts
- On April 30, 2016, Sylvia Schuppe (homeowner) and Darwin Harber (stonemason) signed a written agreement for Harber to install a 400-square-foot stone patio at Schuppe’s home in Simsbury, Connecticut, for about $15,000.
- The written agreement required Harber to ensure the patio had “appropriate drainage,” but it did not specify how drainage would be achieved.
- On May 15, 2016—after the contract was signed—Harber emailed Schuppe proposing to drill four drainage holes in the patio so rainwater would drain away and not pool near the house.
- Schuppe responded by email the same day, agreeing to Harber’s four-hole drainage plan.
- After beginning the work, Harber concluded that four holes would harm the patio’s appearance and, without consulting Schuppe, drilled only three holes.
- Harber completed the patio and Schuppe paid the full contract price.
- Over the next two months, Schuppe observed water pooling on the patio after rainstorms; some water seeped into her basement and caused damage.
- When Schuppe complained, Harber refused to do additional work to address the drainage issue unless Schuppe paid an additional $10,000.
- Schuppe sued in Connecticut state court, including a claim for breach of contract based on Harber’s alleged failure to provide “appropriate drainage.”
- Harber defended by asserting that three holes were appropriate for the patio’s size and that unusually heavy rains in the summer of 2016 caused the pooling.
- At a bench trial, Schuppe offered the May 15 email exchange to show what the parties meant by “appropriate drainage.” Harber objected under the parol-evidence rule, arguing the written contract was complete and final.
- The trial court found “appropriate drainage” ambiguous, admitted the emails to explain the term, and entered judgment for Schuppe. Harber appealed.
Issues
- Whether the contract term “appropriate drainage” was ambiguous, allowing the factfinder to consider evidence outside the four corners of the written agreement.
- Whether the parol-evidence rule barred the admission of the parties’ May 15 emails (sent after contract execution) to explain what “appropriate drainage” meant for this project.
- Whether the trial court’s ruling admitting the emails and entering judgment for Schuppe should be disturbed on appeal.
Decision
- The Connecticut Appellate Court affirmed the judgment for Schuppe.
- It agreed that “appropriate drainage,” as used in the patio contract without technical specifications, was reasonably open to more than one meaning and therefore ambiguous in context.
- Because the term was ambiguous, the trial court was permitted to consider extrinsic evidence to determine the parties’ intent, and the May 15 emails were admissible for that purpose.
- The email exchange supported the trial court’s conclusion that Harber treated four drainage holes as the drainage method contemplated for Schuppe’s patio and that Harber’s unilateral change to three holes, followed by pooling and related damage, supported Schuppe’s breach-of-contract claim.
Legal Principles
- Contract interpretation begins with the language of the written agreement; when a term is reasonably susceptible to more than one meaning in context, the term is ambiguous.
- When a contract term is ambiguous, extrinsic evidence may be admitted to explain the term’s meaning and to show the parties’ intent.
- The parol-evidence rule generally excludes extrinsic evidence offered to vary or contradict the terms of a complete, unambiguous integrated writing; it does not bar evidence used to explain an ambiguous term.
- Communications between the parties after execution of a contract may be considered when offered to clarify the meaning of an ambiguous contractual obligation, rather than to replace the writing with a different bargain.
- After a bench trial, an appellate court gives substantial deference to the trial court’s factfinding and will not overturn findings or related evidentiary rulings absent error.
Conclusion
In Schuppe v. Harber, the court upheld the trial court’s determination that the patio contract’s requirement of “appropriate drainage” was ambiguous and that the parties’ May 15 email exchange proposing and accepting a four-hole drainage plan was admissible to explain that term, supporting judgment for the homeowner on her breach-of-contract claim.