No, that’s not what happened. We don’t have to speculate as to what the Court “probably” did because we have the opinion of the trial court to refer to – that’s what I have been quoting from. Here’s the link – the trial court decision starts at page 19: https://www.supremecourt.gov/DocketPDF/18/18-1356/97268/20190423135448437_Adetu%20Appendix%20E%20File%20Apr%2023%202019.pdf
It is true that the elements of a claim for breach of contract include actionable damages – but in this case the court also held that there was no evidence of material breach; (Elements of breach of contract: (1) a valid contract between the parties; (2) an obligation or duty arising out of contract; (3) a breach of that duty; and (4) damages caused by breach.”). (See page 6 to 7 in the file above, from the court of appeals opinion; and page 27)
The terms of the contract were that Sidwell would pay $50K to the family and that the grades for the Math II and Calculus class would be reviewed in good faith, with no promises made as to outcome; and also that the process of review would be completed by a date certain in September. The teachers did their review well ahead of schedule – the Math II teacher stood firm; the Calculus teacher changed the fall grade from A- to A after realizing that he had mistakenly failed to omit the lowest exam grade for all the students in the class, but he did not revise the spring B+ grade.
[quote]
Although plaintiffs assert that the grade recalculations for the spring 2013 semester of Calculus and
both semesters of Math II were erroneous and therefore breached the settlement agreement, the methodologies employed by Mr. Markey and Ms. Koziebrodzka to perform the recalculations do not violate the express terms of the Settlement Agreement. The Settlement Agreement is silent as to the proper method for recalculating the grades. Moreover, the Settlement Agreement suggests that plaintiffs are required to accept the results of the grade recalculations if they were performed in good faith, as Sidwell “offers no guarantees as to any change in results.”/quote
The school was late in getting the transcripts corrected, but even though they missed the September deadline the transcript was corrected before transmission to any colleges, so it was not a “material” breach as it did not impact the outcome of the agreement.
The trial court held that since there was no evidence of bad faith in the Math II teachers decision to maintain the C/C+ grade, there was no breach of the agreement – because the agreement did not require or mandate that she change the grade.
And the court found that it had been, or at least that the plaintiff had not produced any evidence that it hadn’t.
The trial court did not address the issue of damages – that came up in the Court of Appeals, which decided it didn’t even have to reach the underlying facts because the complaint also failed on the damages element. So the trial court made a determination on elements 1, 2, and 3 of breach of contract; and the Court of Appeals pointed out that it also failed on element 4.