With COVID-19 and Force Majeure, Canceling Deals Is Not OK!
There are strong arguments that businesses should not be able to use a force majeure argument to throw away their contracts, write attorneys Ian Lis and Eli Gordon.
March 30, 2020 at 03:41 PM
5 minute read
The continued spread of COVID-19 has caused a global pandemic like never seen before. The daily lives of individuals are being affected, and the operations of businesses are being interrupted and in certain instances terminated altogether.
Given the financial and personnel uncertainties that COVID-19 has caused, many businesses are seeking creative options to excuse their performance under their existing contracts, whether mergers and acquisitions, financing, manufacturing, distribution, etc.
One main argument that businesses will attempt to use to get out of their contracts is force majeure, Latin for superior force. Most contracts contain force majeure clauses that essentially state that extreme and unforeseen circumstances beyond the control of either party (force majeure events) may excuse a party's performance under the agreement.
However, these force majeure clauses are far from uniform, and many contracts do not adequately articulate what constitutes a force majeure event. For example, a sample construction agreement states that "force majeure shall extend only to events beyond the reasonable foreseeability and control of the contractor and shall include delays directly resulting from fire, strike, labour disputes and delay in delivery of the materials to be supplied by subcontractors, resulting from force majeure as defined herein."
Conversely, a sample loan agreement defines force majeure as "events occasioned by strikes, lockouts, war or civil disturbance, natural disaster or acts of God which cause delay in borrower's performance of an obligation."
If an event is specified in a force majeure clause, then if the specified event occurs, the impacted party (the obligee) is excused from performance. Generally, when the specified event is not listed, this means that the parties allocated the risk of the specified event to the impacted party, or the obligor.
Epidemics and pandemics are usually considered their own specified events for purposes of a force majeure clause. While the terms epidemic and pandemic are not used in the provisions above, the construction agreement's force majeure clause contains a catchall provision for events "beyond the reasonable foreseeability and control of the contractor."
This is almost verbatim phrase given in template documents such as similar "events beyond the [reasonable] control of the impacted party."
How broadly this phrase may be interpreted depends upon the state law interpretation. For example, a Florida court may interpret the phrase to capture only unlisted events that are similar to the listed events. A 2010 Second District Court of Appeal decision in Snavely Siesta Associates v. Senker held that a phrase in a purchase agreement's force majeure clause which excused performance for circumstances the seller's control was tethered to the phrase "such as acts of God, or any other grounds cognizable in Florida contract law as impossibility or frustration of performance" and must be interpreted in conjunction with such.
Additionally, many contracts do not explain whether the presence of a force majeure event merely allows a party to delay performance until it becomes commercially practical to perform or whether such an event allows a party to terminate the contract altogether.
For sellers and other businesses facing force majeure claims from their buyers, vendors or other contracting parties, what can you do? What is your recourse against these parties who are attempting to get out of their agreements because of force majeure? What is the net effect of all of this?
Businesses and their lawyers must identify the scope of contracts that contain force majeure clauses. This process entails reviewing and evaluating whether the force majeure provisions in existing agreements sufficiently explain what constitutes a force majeure event and whether the provision provides for a detailed procedure to be followed if such an event occurs.
This process requires continuous monitoring of state and federal responses to the coronavirus. In the possible event that COVID-19 results in a government-mandated cessation of the impacted business, this would almost certainly trigger a "beyond the control" catchall phrase in a force majeure provision.
If existing force majeure clauses are simple boilerplate provisions that lack the requisite detail, whether the COVID-19 constitutes a force majeure event will be an interpretation question for the courts and arbitrators to determine. Also, if existing force majeure clauses contain catchall phrases for other events "beyond the control" of the impacted party, a careful review of the listed events will be very important to ascertain whether COVID-19 falls in line with the clause's listed events.
In sum, there are strong arguments that businesses should not be able to use a force majeure argument to throw away their contracts. While performance under a contract may in certain circumstances be reasonably delayed, parties must ultimately abide by their contractual obligations. Such is the beauty of the freedom to contract. In 1955, the Florida Supreme Court ruled in Beach Resort Hotel v. Wieder, "It is well settled that courts may not rewrite a contract or interfere with the freedom to contract or substitute their judgment for that of the parties thereto in order to relieve one of the parties from the apparent hardship of an improvident bargain."
Notwithstanding that argument, we expect that COVID-19 will shed new light on this topic and highly recommend that consumers and businesses alike review all important agreements in order to understand how force majeure clauses might impact their contractual relationships.
Ian Lis is a director and Eli Gordon is an associate at Tripp Scott in Fort Lauderdale.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllDivided State Court Reinstates Dispute Over Replacement Vehicles Fees
5 minute readSecond Circuit Ruling Expands VPPA Scope: What Organizations Need to Know
6 minute read'They Got All Bent Out of Shape:' Parkland Lawyers Clash With Each Other
Courts of Appeal Conflicted Over Rule 1.442(c)(3) When Claims for Damages Involve a Husband and Wife
Trending Stories
- 1Armstrong Teasdale's London Creditors Face Big Losses
- 2Texas Court Invalidates SEC’s Dealer Rule, Siding with Crypto Advocates
- 3Quinn Emanuel Has Thrived in China. Will Trump Help Boost Its Fortunes?
- 4Manufacturer Must Provide Details Surrounding Expert’s Livestreamed Inspection, Fed Court Rules
- 5Waterbury Jury Awards $2 Million Verdict Against Eversource
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250