In this case, Universal Development Corporation ("Universal"), Hatti Group RE, LLC ("Hatti Group"), and Harsha Hatti separately appealed judgments entered by the Jefferson Circuit Court in favor of Robbie Dellinger following a jury trial. The trial involved consolidated cases with claims asserted by Hatti, the Hatti Group, and Dellinger.
The Jefferson Circuit Court had previously dismissed Universal from Dellinger's initial action against Hatti and the Hatti Group. However, Universal was later brought back into the litigation when Hatti and the Hatti Group filed a separate action against Dellinger, Universal, and others. The cases were consolidated, and Dellinger asserted a breach-of-contract cross-claim against Universal. The jury found in favor of Dellinger on his claims against Universal and Hatti, awarding him compensatory and punitive damages.
The Supreme Court of Alabama reviewed the appeals. It dismissed the appeals of Hatti Group and Hatti, noting that Hatti's appeal in Hatti v. Universal was invalid because no adverse judgment was entered against Hatti in that case. Hatti's appeal in Dellinger v. Hatti was dismissed as untimely because it was filed more than 42 days after the final judgment.
Regarding Universal's appeal, the court reversed the judgment against Universal and rendered a judgment in its favor. The court held that Dellinger's breach-of-contract claim against Universal was void because it was based on work performed without a general contractor's license, violating Alabama's licensure statutes. The court concluded that Dellinger acted as a general contractor under the Personal Services Agreement with Hatti, and since Dellinger was unlicensed, the contract was void as a matter of public policy. Consequently, Universal had no legal obligation to support Dellinger in seeking payments under an unenforceable contract. View "Universal Development Corporation v. Dellinger" on Justia Law
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