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Eastlake Construction Co. v. Hess

Court of Appeals of Washington
686 P.2d 465 (1984)


Eastlake Construction Company (Eastlake) (plaintiff) entered into a contract with LeRoy Hess and Jean Hess (defendants) to build a five-unit condominium building. Eastlake then sued the Hesses for breach of contract to recover the $13,719 allegedly owed on the contract. The Hesses counterclaimed, alleging that Eastlake had breached the contract and caused the Hesses damages. The trial court awarded the Hesses damages for breach of contract, minus the amount still owed to Eastlake under the contract. However, the trial court declined to award the replacement cost of improperly installed kitchen cabinets, finding that this would constitute unreasonable economic waste. Instead, the trial court measured damages by calculating the difference between the value of the specified cabinets and the cost of the cabinets actually installed. Further, the trial court declined to award damages on nine other breaches, because those breaches did not result in substantial damage or a substantial loss of value. Both Eastlake and the Hesses appealed.

Rule of Law


Holding and Reasoning (Pearson, J.)

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