McKinney v. LaMalfa Party Ctr.

Summary

The Ohio Eleventh District Court of Appeals affirmed a judgment awarding Brianna McKinney a $5,000 refund from LaMalfa Party Center. The court held that LaMalfa materially breached the wedding-reception contract by unilaterally imposing COVID-19 restrictions that substantially altered the contracted-for event, notwithstanding the contract's no-refund provision. The court also held that McKinney's complaint provided sufficient notice of a breach-of-contract claim despite describing her theory as impossibility of performance.

Holdings

1. The magistrate's finding that McKinney did not wish to proceed with the reception under LaMalfa's restrictions was a reasonable inference from her testimony and was supported by competent, credible evidence.
2. Impossibility of performance is an affirmative defense to a breach-of-contract claim, not an independent cause of action for recovering damages; however, McKinney's complaint gave LaMalfa fair notice of the operative claim, and its failure to expressly label the claim as breach of contract did not bar recovery.
3. LaMalfa materially breached the wedding-reception contract by unilaterally imposing COVID-19 restrictions that substantially altered the contracted reception, including replacing the buffet and imposing restrictions affecting every guest, despite the contract's provision that its terms could not be changed after signing.
4. McKinney was entitled to recover $5,000 because the refund restored her to the position she would have occupied had LaMalfa not breached; LaMalfa could not rely on the no-refund provision after materially altering and breaching the contract.

Questions Presented

1. Whether the magistrate's factual finding that McKinney did not wish to proceed under LaMalfa's COVID-19-related changes was supported by competent, credible evidence.
2. Whether McKinney's reference to impossibility of performance stated a legally cognizable claim and whether her complaint gave LaMalfa fair notice of a breach-of-contract claim.
3. Whether LaMalfa's unilateral COVID-19-related changes materially breached the wedding-reception contract.
4. Whether McKinney was entitled to recover the $5,000 deposit despite the contract's provision that deposits were nonrefundable upon cancellation.

Disposition

affirmed