Monday, June 22, 2009

Fourth District Affirms Trial Court's Interpretation of Warranty in Contract

In Detroit Diesel Corporation v. Atlantic Mutual Insurance Company (4D08-1593), the Fourth District affirmed the trial court's interpretation of a contract.

The Fourth District stated:

This appeal presents the question of whether the trial court correctly interpreted the limited warranty to cover engine repairs during the warranty period resulting from defects in material or workmanship, not limited to defects in material or workmanship of “major components.”


The determination of whether a contract is unambiguous and the interpretation of an unambiguous contract are questions of law subject to de novo review on appeal. Smith v. Shelton, 970 So. 2d 450, 451 (Fla. 4th DCA 2007). “Whether a document is ambiguous depends upon whether it is reasonably susceptible to more than one interpretation. However, a true ambiguity does not exist merely because a document can possibly be interpreted in more than one manner.” Lambert v. Berkley S. Condo. Ass’n, 680 So. 2d 588, 590 (Fla. 4th DCA 1996) (citation omitted). “When contractual language is clear and unambiguous, courts cannot indulge in construction or interpretation of its plain meaning.” BMW of N. Am., Inc. v. Krathen, 471 So. 2d 585, 587 (Fla. 4th DCA 1985). The language of the warranty is clear and unambiguous. The plain language of the warranty states that the warranty covers engine repairs to correct any malfunction resulting from defects in “material or workmanship.” The second warranty period does not limit the scope of coverage to merely defects resulting from a “major component,” nor does it require that a “major component” must be the primary cause of the engine malfunction. The second warranty period merely defines the “major components” that are specifically covered during that period, should they be damaged as a result of defects in material or workmanship, without limitation.

We hold that the trial court properly interpreted this warranty and, as such, we affirm.


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