Dittrick v. Chalfant

Summary

Case Description: The parties disputed the proper construction of their written agreement. The court found that the document was both patently ambiguous and incomplete with respect to an interest rate term, and that the missing interest rate was supplied by statute, Del. Code Ann. tit. 6, § 2301(a). Having determined that the legal rate of interest applied to the contract, the court had to decide the appropriate relief. The purchasers requested specific performance. The court found that the balance of the equities supported their request for specific performance. Even assuming that an interest rate provision in an installment land sale contract was essential, the court was not supplementing the agreement through its own judicial discretion. Rather, the law, through § 2301(a), was supplying the interest term. Since inhabiting the property, the purchasers has made substantial improvements and performed a sizable portion of the contract. They undertook these tasks with the expectation that they were on their way to owning their home. Denying them the opportunity to specifically perform the contract would work an inequitable forfeiture of their reasonable expectations and interests.

Proceedings Description: Appeals the Court of Chancery ruling. Petitioner also rebuts Respondents jurisdictional argument.

Outcome: The Supreme Court of Delaware affirms the Court of Chancery ruling.