Legal Brief - Week 06 - Pittsley vs Hilton

Pittsley v. Hilton

 

Case Facts

           

Jane Pittsley (Pittsley) contracted with Hilton Contract Carpet Co. (Hilton), to install carpet in her house for a total price of $ 4,402 in September 1998. Although Pittsley paid Hilton the initial fee of $700, she was not satisfied by finding defective in many areas of the installation. Hilton attempted several times to fix the faulty areas but Pittsley was still not satisfied and instead requested that:

·         the contract be rescinded,

·         the amount of $3,500 paid so far be returned,

·         And the incidental damages to be paid.

The magistrate determined that the contract could not be rescinded because none of the parties committed a breach and awarded Pittsley $400 ($250 damages plus $150). Hilton counterclaimed for the balance due on the contract was awarded the remaining balance of $902.

Pittsley decided to appeal to the district court, evoking that the contract is considered under the Idaho Uniform Commercial Code (UCC) because the carpets ordered were parts of “goods”. Hilton disagreed with Pittsley and mentioned that the issue was in the installation, not the materials. The district court returned the case to the magistrate for reconsideration and to apply the UCC to the transaction.

 

The Issue

The main issue is to conclude whether or not this transaction can be governed by the Idaho UCC?

Rule

 

In General, the UCC applies only to the sale of “goods”. Therefore, it is erroneous to apply the UCC rule for the transaction that involves real estate, services, and stock.

The Idaho UCC – Sales defines “goods” as “all things (including specially manufactured goods) which are movable at the time of identification to the contract for sale other than the money in which the price is to be paid, investment securities (chapter 8) and things in action. "Goods" also includes the unborn young of animals and growing crops and other identified things attached to realty as described in the section on goods to be severed from reality.”

Nevertheless, a hybrid transaction can involve both goods and services, which led to conflicts with the purpose of the UCC. Under such transactions, courts established conflicting tests and precedents.

 

Application

           

            Pittsley versus Hilton is an example of a hybrid transaction. She was in quest of obtaining a carpet of a certain quality and color. The contract indicates the supplying of “175 yards Masterpiece #2122-Installed” for $4,319.50 and an additional charge of $82.50 for removing the existing carpet.

Although Pittsley paid Hilton the amount of $3,500, she was not satisfied with the service received as per the agreement entered in September of 1998. Her request of fixing the installation was legitimate and Hilton make some efforts to repair the defective areas.

            Based on the contractor’s willingness to satisfy the client’s needs, the magistrate found that rescission, as an equitable remedy to cancel the contract, was only available when one party committed a breach. Furthermore, the court found that the primary purpose of the contract was the sale of carpet and that the installation service was secondary.

 

Ruling

 

The contract was more about buying a specific brand of carpets and the installation was included in the purchase fee. Therefore, Article 2 of the UCC applies to this case.

 

Reference

Michael H (2021). “Business Law.”

Brigham Young University - Idaho, Chapter 11

Idaho Legislature. “Idaho Statute”. 2021

https://legislature.idaho.gov/statutesrules/idstat/title28/t28ch2/sect28-2-105/. (Accessed 23 October 2021)

 

 

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