Wayment v. Schneider Automotive Group L.L.C.

Brett Wayment (plaintiff), a professional golfer, made a hole-in-one at the eighth hole in a charity golf tournament sponsored by Schneider Automotive Group L.L.C. and Nate Wade Subaru (Wade) (defendants). Rule sheets placed in participants’ golf carts described the tournament format and identified a hole-in-one contest at the eighth hole. When Wayment made the hole-in-one, he believed that he had won a new 2015 Subaru XV Crosstrek that was parked next to the tee box along with a sponsorship sign with Wade’s name and logo. Days later, when Wade discovered that Wayment was a professional golfer, it refused to deliver the car, contending that it never expected professional golfers would compete for tournament prizes without disclosing their professional status, which Wayment never did. And although that condition was never communicated to tournament golfers, Wade’s insurance policy for the tournament required that the hole-in-one be made by an amateur. Wayment sued Wade for breach of contract, alleging that he accepted Wade’s unilateral offer to give him the car when he made the hole-in-one. Wade countered that professional golfers were excluded from the contest, and Wade proffered an expert who testified that while he personally would not feel eligible to win a prize in a charity tournament without first checking the rules, it could be reasonable for Wayment to believe that he was eligible. Despite the lack of written rules regarding whether professional golfers were eligible for tournament prizes and a difference of opinion among experts whether there was a generally accepted custom in the golf community that barred professional golfers from winning prizes in charity golf tournaments, the trial court granted summary judgment to Wayment on his breach-of-contract claim after finding that Wade failed to communicate any restriction on eligibility for the prize and, therefore, it was reasonable for Wayment to believe that he could win the car by making the hole-in-one. Wade appealed, arguing that the case involved a factual question that precluded summary judgment.