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Keywords

contractsettlementbreach of contractdamagesmotionsummary judgmentmotion for summary judgment

contractsettlementbreach of contractplaintiffdamagesmotionsummary judgmentmotion for summary judgment

Related Cases

Fields v. United States, 147 Fed.Cl. 352

Facts

Patricia Fields was employed as an athletic trainer until her termination in February 2011. After her termination, she struggled with PTSD and sought accommodations but was unsuccessful in securing employment despite applying for various positions. In 2013, she entered into a settlement agreement with the Agency, which included commitments regarding her employment record. Fields alleged that the Agency breached this agreement, leading to lost wages and emotional distress, but the Government contended that she could not prove causation or damages.

Plaintiff was employed as an athletic trainer from June 7, 2010 until her termination on February 4, 2011. Plaintiff claims that she struggled with PTSD during her employment with the Agency and had requested accommodations for her PTSD and mental health conditions prior to her removal.

Issue

Did Patricia Fields establish that the United States' breach of the settlement agreement caused her damages, including lost wages and emotional distress?

Rule

To recover damages for breach of contract, a party must establish a valid contract, an obligation arising from that contract, a breach of that obligation, and damages caused by the breach. Damages must be reasonably foreseeable, caused by the breach, and proved with reasonable certainty.

To recover damages for breach of contract, a party must allege and establish: (1) a valid contract between the parties, (2) an obligation or duty arising out of the contract, (3) a breach of that duty, and (4) damages caused by the breach.

Analysis

The court analyzed whether Fields could prove that the breach of the settlement agreement caused her to lose employment opportunities. It concluded that Fields did not provide sufficient evidence to demonstrate that she would have secured employment but for the Agency's breach. The court found her claims of lost opportunities to be speculative and insufficient to establish a causal link between the breach and her alleged damages.

The court agrees with the Government. Plaintiff has failed to demonstrate that she would have been selected for one of the positions that she claims she would have applied to had the personnel file she received in April 2016 contained no references to her termination and included documentation that she resigned due to personal and family medical reasons and had she been informed of the results of the investigations.

Conclusion

The court granted the Government's motion for summary judgment, concluding that Fields failed to prove that the breach of the settlement agreement caused her any damages.

The Court, therefore, GRANTS the Government's motion for summary judgment.

Who won?

The United States prevailed in the case because the court found that Patricia Fields did not establish a causal connection between the alleged breach and her claimed damages.

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