Deauville Hotel Management v. Ward

Kemesia and Patrick Ward (plaintiff) entered into a wedding-reception-hosting contract with Deauville Hotel Management (DHM) (defendant) under which DHM would provide both a reserved function space and catering services. All communications between DHM and the Wards identified the hotel’s Richelieu ballroom as the Wards’ assigned function space. The contract further stated that DHM would provide a comparable alternative if DHM needed to reassign the Wards’ reserved function space. Shortly before the Wards’ wedding, the City of Miami Beach shut down the Richelieu ballroom for safety violations. The Wards were not informed about the shutdown until the morning of their wedding. DHM moved the Wards’ reception from the Richelieu ballroom to the hotel lobby. The lobby was significantly smaller than the ballroom, did not have an ocean view, and did not allow for any separation between hotel guests and wedding guests. The Wards did receive the promised catering services, and the Wards’ wedding incidentals, including their flowers, DJ, and wedding cake, were set up in the lobby. The Wards sued DHM for breach of contract and sought $23,000 in compensatory damages. The $23,000 request included the approximately $13,000 contract value plus the standard cost to rent the Richelieu ballroom independently and the cost of the Wards’ wedding incidentals. The Wards sought to recover the rental cost for the Richelieu ballroom even though the rental cost was included in the $13,000 wedding reception contract charge; the Wards were never charged a separate, additional ballroom rental fee. The jury found that DHM had breached the Wards’ contract and awarded the Wards $23,000 in compensatory damages. DHM appealed, arguing that the compensatory damages award was excessive and that the contract had not been breached, because the lobby was a comparable alternative to the Richelieu ballroom.