Pleasant Grove Independent School District v. FieldTurf USA Inc. and Altech, Inc.
Pleasant Grove Independent School District v. FieldTurf USA Inc. and Altech, Inc. (2022)
Winning Party
FieldTurf USA Inc.
Key Issue
Breach of Warranty
Case Type
CIVIL
Facts
•
The field was warranted for eight years but started degrading within five years.
•
The warranty language explicitly limited the remedy to repair or replacement.
•
FieldTurf refused to replace the field, claiming that the field problems were merely cosmetic and presented no playability or safety hazards.
•
The District notified FieldTurf that the field was degrading and its fibers were becoming brittle, causing color loss and loss of traction.
•
The District sought damages measured by the turf's replacement cost.
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Pleasant Grove Independent School District contracted with Altech, Inc. for the construction of a new football stadium.
•
FieldTurf's inspection concluded that the field was showing signs of accelerated wear in all the fiber colors.
•
The trial court instructed the jury to consider the difference in value between the goods accepted and the value they would have had if they had been as warranted.
•
The artificial-turf field was a Prestige XM-60 field with Duraspine fibers.
•
The warranty limited the remedy to repair or replacement of the affected area.
•
FieldTurf representatives admitted the field was in bad condition and that other fields were failing at a large rate.
•
The District waived all other remedies.
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The District rejected FieldTurf's proposal to repair the field and instead installed a new field.
•
The District complained to FieldTurf about the field's premature wear and degradation and demanded that FieldTurf replace the field under warranty.
•
The District argued that the measure of damages should have been the cost to repair or replace the field.
•
The District presented evidence of the field's initial purchase price and the cost of replacement but not the difference in market value.
•
FieldTurf provided an eight-year limited warranty on the artificial-turf field.
•
The District admitted at trial that there was no evidence to support the damage measure based on the difference in market value.
•
Altech, Inc. subcontracted with FieldTurf USA to manufacture and provide an artificial-turf field.
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Key Holdings
•
The jury was properly instructed on damages because the instruction accurately stated the law under Section 2.714(b) of the Texas Business and Commerce Code, which provides for the difference in value between the goods accepted and the value they would have had if they had been as warranted.
•
The District was not entitled to recover money damages because the warranty explicitly limited the remedy to repair or replacement of the defective turf.
•
The District failed to produce evidence of the difference in market value between the field as accepted and the field as warranted, which is the proper measure of damages under Section 2.714(b) of the Texas Business and Commerce Code, even if the warranty failed of its essential purpose.
Legal Reasoning
The court reasoned that the warranty language clearly and unambiguously limited the remedy to repair or replacement, precluding recovery of monetary damages. The court also found that the jury was properly instructed on the measure of damages, which is the difference in value between the goods as accepted and as warranted. Finally, the court concluded that the District failed to present evidence of the difference in market value, which is necessary to recover damages for breach of warranty.
Outcome
The court reversed the jury's award of damages and rendered a take-nothing judgment in favor of FieldTurf.
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