Los Angeles Superior Court Grants Motion for New Trial After Finding Jury Verdict Legally Inconsistent

Decker Law Obtains New Trial in Construction Dispute Based on Irreconcilably Inconsistent Special Verdict

Decker Law successfully obtained an order granting a motion for new trial in Los Angeles Superior Court after the court determined that a jury returned a legally inconsistent special verdict in a construction dispute involving residential pool construction.

The ruling vacated a judgment entered after a nine-day jury trial and ordered a new trial on the contractor's Cross-Complaint, concluding that the verdict was contrary to law because the jury simultaneously found the existence of an enforceable contract while awarding damages on a quantum meruit theory that could not legally coexist with that finding.

Background of the Case

The dispute arose from the construction of a residential pool, spa, waterfall, barbecue area, and deck.

The homeowners alleged that the contractor failed to properly construct portions of the project and caused construction delays. The contractor denied those allegations and filed a cross-complaint seeking unpaid compensation for work performed on the project.

Following a nine-day jury trial, the jury rejected all of the homeowners' affirmative claims and awarded the contractor $18,107.39 on a common count theory for goods and services rendered.

After judgment was entered, the homeowners retained Decker Law to challenge the verdict through a motion for new trial.

The Legal Issue

The key issue involved the relationship between contract claims and quantum meruit claims.

The jury specifically found that:

• A valid contract existed between the parties;

• The homeowners breached that contract; and

• The contractor suffered no recoverable contract damages.

At the same time, however, the jury awarded the contractor damages for the reasonable value of goods and services rendered under a quasi-contract theory.

That created a legal problem.

Under California law, a party generally cannot recover in quantum meruit when an enforceable contract governs the same subject matter. Once a valid contract exists, recovery ordinarily must be based on the contract itself rather than an implied contract theory.

The Motion for New Trial

Decker Law argued that the special verdict was irreconcilably inconsistent.

The motion explained that the jury could not simultaneously find:

1. The parties entered into an enforceable contract covering the work at issue; and

2. The contractor was entitled to recover under a quantum meruit theory for the same work.

The motion further argued that the resulting judgment was contrary to California law and therefore warranted a new trial under Code of Civil Procedure section 657.

The Court’s Decision

The trial court granted the motion.

Relying on California authority governing contract and quantum meruit claims, the court concluded that the verdict was legally inconsistent because the jury found both the existence of a valid contract and entitlement to recovery for goods and services rendered.

The court explained that once the jury determined an enforceable contract existed, recovery in quantum meruit was unavailable as a matter of law because the contract governed the same subject matter.

The court therefore held:

"The award for reasonable value for goods and services in quantum meruit ... is an error and irreconcilably inconsistent with the jury finding that the parties entered into a contract."

Defendants' Arguments Rejected

The contractor argued that the jury may have intended to compensate work performed outside the scope of the written contract.

The court rejected that argument, finding there was insufficient support in the record and noting that courts are not permitted to speculate about what the jury might have intended when evaluating a special verdict.

The contractor also argued that the homeowners waived any challenge to the verdict by failing to object before the jury was discharged.

The court rejected that argument as well, holding that no objection was required because the inconsistency was fatal and rendered the verdict irreconcilable.

Finally, the contractor argued that any error was harmless.

The court disagreed, concluding that the problem was not a technical defect in the verdict form itself but a substantive inconsistency in the jury's findings.

The Result

The court granted the motion for new trial and ordered a new trial on the contractor's cross-complaint. The judgment entered on the cross-complaint could not stand because the jury's findings were legally inconsistent and contrary to California law.

Why This Decision Matters

Post-trial motions are often the last opportunity to correct serious errors before an appeal.

This case demonstrates that even after a lengthy jury trial and an adverse verdict, relief may be available when the verdict is inconsistent, unsupported by law, or otherwise defective. Courts retain authority to set aside verdicts that cannot be reconciled under governing legal principles.

The ruling also highlights the importance of carefully analyzing special verdict forms and jury findings after trial. In some cases, a verdict that appears favorable on its face may contain internal contradictions that justify post-trial relief.

Contact Decker Law

Decker Law represents businesses, property owners, contractors, and individuals in post-trial motions, motions for new trial, appeals, writ proceedings, and complex civil litigation throughout California.

If you believe a jury reached an inconsistent verdict or a judgment was entered contrary to law, contact Decker Law to discuss your options.