Utah Court of Appeals
When should implied contract claims go to a jury instead of being resolved on summary judgment? Wayment v. Schneider Automotive Group Explained
Summary
Brett Wayment, a professional golfer, made a hole-in-one at a charity tournament sponsored by Nate Wade Subaru, which had parked a new car near the tee box. When Nate Wade refused to award the car, claiming professionals were ineligible, Wayment sued for breach of contract. The district court granted summary judgment to Wayment, finding Nate Wade’s limitation to amateur golfers was not communicated to participants.
Analysis
The Utah Court of Appeals in Wayment v. Schneider Automotive Group provides valuable guidance on when implied-in-fact contract disputes should proceed to trial rather than be resolved through summary judgment.
Background and Facts
Brett Wayment, a professional golfer, participated in a charity tournament sponsored by Nate Wade Subaru. At the eighth hole, participants found a new Subaru parked near the tee box with Nate Wade’s sponsorship sign and tournament rules indicating a hole-in-one contest. When Wayment made a hole-in-one, he expected to receive the car. However, Nate Wade refused delivery, claiming that professional golfers were ineligible—a limitation never communicated to participants but required by their insurance policy covering the contest.
Key Legal Issues
The central question was whether an implied-in-fact contract existed between Nate Wade and Wayment for a unilateral contract prize contest. Expert testimony revealed conflicting views within the golf community about whether professional golfers are typically eligible for such prizes, with no uniform standard governing the issue.
Court’s Analysis and Holding
The Court of Appeals reversed the district court’s summary judgment ruling. While the existence of an express contract is ordinarily a question of law, the court emphasized that implied-in-fact contracts depend on the objective manifestations of the parties’ intent and are “primarily a jury question.” The court found that reasonable minds could differ on whether Nate Wade’s conduct—the sponsorship sign, parked car, and rule sheet—communicated an offer that included professional golfers. The lack of uniform standards in the golf community regarding professional eligibility further supported the conclusion that factual disputes precluded summary judgment.
Practice Implications
This decision reinforces that courts should exercise caution when resolving implied contract disputes on summary judgment. When contractual intent must be inferred from conduct rather than express terms, and when industry experts acknowledge a lack of uniform standards, these factual questions should typically proceed to trial. The case also highlights the importance of clear communication in promotional contests to avoid ambiguity about eligibility requirements.
Case Details
Case Name
Wayment v. Schneider Automotive Group
Citation
2019 UT App 19
Court
Utah Court of Appeals
Case Number
No. 20161090-CA
Date Decided
January 31, 2019
Outcome
Reversed
Holding
The existence of an implied-in-fact contract is a question of fact for the jury when reasonable minds could differ regarding the meaning of the parties’ objective manifestations.
Standard of Review
Correctness for summary judgment rulings
Practice Tip
In implied-in-fact contract cases, resist summary judgment when expert testimony reveals a lack of uniform industry standards, as this often demonstrates that reasonable minds could differ on the parties’ intent.
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